WinkUp Privacy Agreement

Updated: 2025-04-16

When using the WinkUp app, we will properly handle your personal information in accordance with the WinkUp Privacy Agreement, including the collection, storage, use and external sharing of information. This agreement is designed to detail how we can help you safely access, update, manage and protect your personal information while providing convenient services. We are well aware of the importance of privacy and security of personal information to users. WinkUp is committed to taking reasonable security measures to protect your data and avoid any unauthorized access, disclosure or abuse.

We hope that you will carefully read and fully understand each clause in the agreement so that you can clearly understand your rights and obligations and our commitment to privacy protection. If you do not agree to the relevant terms, please do not use this application. We will update the agreement regularly in the future to ensure that the content complies with the latest laws, regulations and privacy protection requirements, and will remind you to read the new version after the agreement is updated to help you understand how we protect your information at any time.

1 Collection and Use of Personal Information

(1) One-click Login Convenient Service

WinkUp provides you with a quick and convenient one-click login function. After the user authenticates and explicitly agrees to this Privacy Agreement and User Agreement, the system will automatically bind your device ID and other information to quickly complete the login process. After logging in, you can choose whether to complete your avatar, nickname, personal profile, preferences and other information according to your personal preferences to customize your exclusive WinkUp space.

(2) Intelligent Association of Account Information

After successful login, your usage history will be automatically associated with your WinkUp account to better optimize your experience. When we provide location-based content or services, we will only use your geographic location information after you explicitly authorize it to protect your privacy.

(3) Respect for Multimedia Sharing Permissions

When you want to shoot or share audio, video or pictures to the WinkUp platform, we will politely request camera, photo album, microphone and other permissions based on actual functional requirements. If you choose to refuse authorization, some sharing functions may be affected, but you can still continue to enjoy WinkUp's other rich functions to ensure that your overall experience is not affected.

(4) In-depth customization of personalized content

In order to provide you with more accurate personalized services, WinkUp will collect necessary information after obtaining your authorization and analyze your interests and preferences through intelligent algorithms. Based on these analyses, we will recommend content and services that better meet your needs to enhance your user experience. We promise to follow the principle of data minimization, collect only the information required to provide personalized services, and always put your privacy protection first.

2 Sharing, transfer and public disclosure of personal information

(1) We will only share your personal information with third parties in the following specific circumstances to ensure that your data security and privacy are fully protected:

1) Sharing based on explicit consent: We will only share your personal information with third parties after obtaining your explicit authorization to ensure that your right to know and right to choose are fully respected.

2) Laws, regulations and government requirements: In accordance with the requirements of relevant laws and regulations, or when we receive mandatory instructions from government authorities, we may need to share your personal information to fulfill corresponding legal obligations.

3) Sharing with authorized partners: In order to achieve the service purposes described in this Privacy Agreement, we may share necessary personal information with authorized partners. This information is limited to the provision of specific services, and partners have no right to use the shared information for other purposes. We always ensure that sharing is based on legal, legitimate, necessary, specific and clear purposes, and take strict security measures to prevent data from being abused or leaked.

(2) Regarding the transfer of personal information, we adhere to the strict restriction principle and only transfer it in the following circumstances:

1) Transfer with explicit consent: After obtaining your explicit authorization, we will transfer your personal information to other parties to ensure that your privacy rights are not violated.

2) Corporate changes and asset disposal: In cases involving mergers, acquisitions, asset transfers or bankruptcy liquidation, if personal information is transferred, we will require the new information holder to continue to be bound by this Agreement and protect your personal information in accordance with laws and regulations and security standards that are no less stringent than those required by this Agreement. Otherwise, we will re-ask for your authorization and consent.

(3) We will only publicly disclose your personal information in the following specific circumstances and will take security measures that meet industry standards to ensure information security:

1) Disclosure based on explicit consent: We will only publicly disclose your personal information after obtaining your explicit authorization to ensure that your right to know and right to choose are respected.

2) Legal and litigation requirements: We may publicly disclose your personal information in response to legal provisions, legal procedures, litigation or mandatory requirements of government authorities to fulfill legal obligations or cooperate with judicial and administrative procedures.

3) Announcement of violations and fraudulent behavior: In order to combat illegal accounts and fraudulent behavior on the platform, we may publicly disclose relevant information to maintain the order of the platform and the legitimate rights and interests of other users.

(4) In addition, in accordance with laws, regulations and national standards, we can share, transfer or publicly disclose your personal information without your authorization and consent in the following special circumstances:

1) Situations directly related to national security and national defense security;

2) Situations directly related to public security, public health and major public interests;

3) Situations directly related to criminal investigation, prosecution, trial and execution of judgments;

4) Situations for the purpose of safeguarding your or other individuals’ major legitimate rights and interests such as life and property but it is difficult to obtain your consent;

5) Personal information that you disclose to the public on your own;

6) Personal information collected from legally disclosed information, such as information obtained from legal news reports, government information disclosure and other channels.

3 Sharing, transfer and public disclosure of personal information

(1) We will only share your personal information with third parties in the following specific circumstances to ensure that your data security and privacy are fully protected:

1) Sharing based on explicit consent: We will only share your personal information with third parties after obtaining your explicit authorization to ensure that your right to know and right to choose are fully respected.

2) Laws, regulations and government requirements: In accordance with the requirements of relevant laws and regulations, or when we receive mandatory instructions from government authorities, we may need to share your personal information to fulfill corresponding legal obligations.

3) Sharing with authorized partners: In order to achieve the service purposes described in this Privacy Agreement, we may share necessary personal information with authorized partners. This information is limited to the provision of specific services, and partners have no right to use the shared information for other purposes. We always ensure that sharing is based on legal, legitimate, necessary, specific and clear purposes, and take strict security measures to prevent data from being abused or leaked.

(2) Regarding the transfer of personal information, we adhere to the strict restriction principle and only transfer it in the following circumstances:

1) Transfer with explicit consent: After obtaining your explicit authorization, we will transfer your personal information to other parties to ensure that your privacy rights are not violated.

2) Corporate changes and asset disposal: In cases involving mergers, acquisitions, asset transfers or bankruptcy liquidation, if personal information is transferred, we will require the new information holder to continue to be bound by this Agreement and protect your personal information in accordance with laws and regulations and security standards that are no less stringent than those required by this Agreement. Otherwise, we will re-ask for your authorization and consent.

(3) We will only publicly disclose your personal information in the following specific circumstances and will take security measures that meet industry standards to ensure information security:

1) Disclosure based on explicit consent: We will only publicly disclose your personal information after obtaining your explicit authorization to ensure that your right to know and right to choose are respected.

2) Legal and litigation requirements: We may publicly disclose your personal information in response to legal provisions, legal procedures, litigation or mandatory requirements of government authorities to fulfill legal obligations or cooperate with judicial and administrative procedures.

3) Announcement of violations and fraudulent behavior: In order to combat illegal accounts and fraudulent behavior on the platform, we may publicly disclose relevant information to maintain the order of the platform and the legitimate rights and interests of other users.

(4) In addition, in accordance with laws, regulations and national standards, we can share, transfer or publicly disclose your personal information without your authorization and consent in the following special circumstances:

1) Situations directly related to national security and national defense security;

2) Situations directly related to public security, public health and major public interests;

3) Situations directly related to criminal investigation, prosecution, trial and execution of judgments;

4) Situations for the purpose of safeguarding your or other individuals’ major legitimate rights and interests such as life and property but it is difficult to obtain your consent;

5) Personal information that you disclose to the public on your own;

6) Personal information collected from legally disclosed information, such as information obtained from legal news reports, government information disclosure and other channels.

4 Cookies and similar technologies

Cookies and similar technologies are commonly used tools in the Internet field. When you use our products or services, we may use these technologies to automatically identify your information and record it as log data. You can choose to clear the cookies on your computer or enable the "Do Not Track" function provided by most browsers. The main purposes for which we use these technologies include:

(1) Ensuring the security and efficient operation of products and services

We may use authentication and security cookies or anonymous identifiers to verify your identity to ensure the security of your account. These technologies also help improve service efficiency, speed up response, and optimize overall performance.

(2) Improving a smooth user experience

Through these technologies, we can simplify your operation process and avoid repeatedly entering personal information or searching for content. At the same time, we record your personalized settings, such as layout and appearance preferences, to provide you with services that are more in line with your personal preferences.

(3) Accurately recommend personalized content

We use cookies and similar technologies to gain a deeper understanding of your preferences and usage habits for data analysis, and then continuously improve our products and services. Based on these analyses, we will recommend content that is more in line with your interests and optimize the advertising experience to make it more relevant.

5 Your rights

In accordance with relevant national laws, regulations, national standards, and industry practices, we guarantee that you can exercise the following rights to your personal information. The scope and method of your access, modification and deletion of personal information will depend on the specific services you use:

(1) Access your personal information

You have the right to access and manage your personal information, except for special circumstances stipulated by laws and regulations. If you wish to exercise your data access rights, you can do so in the following ways:

You can view or edit the personal information in your account, change your password, or add security information by clicking on the "My" page in the lower right corner of the app to enter the personal center. Click on the avatar to perform the corresponding information modification and management operations to ensure that your information is always up to date.

(2) Correct your personal information

In general, you can directly delete the content you posted and browse, modify, and delete the information you submitted at any time. However, for security and identity recognition reasons, you may not be able to modify certain initial login information submitted when logging in.

(3) Deleting your personal information

You may request us to delete your personal information in the following circumstances:

1) If our handling of personal information violates laws and regulations;

2) If we collect and use your personal information without your consent;

3) If our handling of personal information violates our agreement with you;

4) If you no longer use our App or service;

5) If we no longer provide you with this App or service.

(4) You may cancel your previously logged-in account at any time. You may apply to us to cancel your account by email. Before canceling your account, we will verify your personal identity, security status, device information, etc. The act of canceling an account is irreversible. After canceling your account, we will delete all information about your App account or anonymize the relevant information.

(5) How we respond to your request

For security reasons, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request, and we will respond within thirty working days. In the following circumstances, we will not be able to respond to your request in accordance with laws and regulations:

1) Directly related to national security and national defense security;

2) Directly related to public security, public health, and major public interests;

3) Directly related to criminal investigation, prosecution, trial, and execution of judgments;

4) There is sufficient evidence that you have subjective malice or abuse of rights;

5) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

6) Involving commercial secrets.

6 How we store personal information

All personal information collected and generated by this application in China will be stored in China. We will not transfer your information overseas. If some functions involve cross-border business and need to transfer relevant information to overseas institutions, we will strictly comply with relevant national regulations and obtain your explicit consent in advance. At the same time, we will ensure that overseas institutions treat your personal information confidentially and ensure its data security through effective measures such as signing agreements and on-site inspections in accordance with laws, regulations and regulatory requirements.

7 Protecting personal information

This application strictly abides by national laws and regulations to ensure the security of personal information processing and prevent unauthorized access and information leakage, tampering, and loss risks.

(1) Personal information protection: Users have the right to refuse to provide us with some personal data. We respect user privacy preferences and provide setting options to adjust data usage preferences. We prohibit the sale of personal data. If you encounter problems or need to understand the agreement, please contact the customer service team.

(2) Security technology: We use industry-standard encryption technology, combined with de-identification and anonymization methods to protect information. Deploy multiple defense mechanisms to ensure the security of information transmission and storage.

(3) Management system: Establish a professional security management department and establish a security management system and data protection process. Implement strict authority management, strengthen information security training for all employees, and conduct regular security audits.

(4) Emergency response: Develop emergency plans for personal information security incidents and organize drills regularly. Once a security incident occurs, immediately activate the plan, notify users as soon as possible according to regulatory requirements, and provide detailed information and remedial measures.

8 Protocol Updates

WinkUp reserves the right to revise the terms of this Agreement at any time, and will ensure that all modifications or updates are prominently marked on this page for your convenience. If you are dissatisfied with the contents of the newly revised agreement, it is recommended to immediately stop using the WinkUp platform and related services. By continuing to access or use our products or services, you fully understand and voluntarily accept all revised terms. The following situations are considered major changes to this application:

(1) Changes in core business model: If our core business model undergoes fundamental changes, it may affect your way and experience of using WinkUp.

(2) Major adjustments in ownership or organizational structure: including major changes in company ownership or management caused by business strategy adjustments, financial reorganization, bankruptcy liquidation, corporate mergers and acquisitions and other events.

(3) Major adjustments to personal information processing policies: Especially when the main recipients of information sharing, transfer or public disclosure change, we will ensure that you understand the possible impact of these changes.

(4) Significant changes in personal information rights and methods of exercise: For example, significant changes in the procedures or conditions for accessing, correcting, and deleting personal information.

9 Contact us

We are well aware that the protection of the rights of users' personal information subjects is very important. Therefore, we have specially set up a personal information protection specialist and opened a special personal information feedback channel to ensure that your voice can be heard in a timely manner and properly handled. If you have any complaints, suggestions or questions about our privacy policy or the handling of personal information, we sincerely invite you to contact our Data Security Officer Dawson, who can be communicated at the following email address: bluceglaesser@gmail. com. At the same time, you can also contact our customer service team through WinkUp's official email "support@winkup.com". Our professional team will be happy to help you and answer your questions. We are always committed to protecting your personal privacy and look forward to your valuable comments and suggestions.