LegionSpace - Privacy Protection Policy

LegionSpace Privacy Protection Policy

Important tips

LegionSpace application knows the importance of personal information to you. We will take corresponding security protection measures according to the requirements of laws and regulations, and try our best to protect your personal information safe and controllable. In view of this, we formulate this privacy protection policy (hereinafter referred to as this policy/this privacy policy ") and remind you that:

This policy is applicable to all products and services provided by LegionSpace application. If the products or services provided by LegionSpace application are used in our products or services (e.g. login with the account of LegionSpace application) but there is no independent privacy policy, this policy is also applicable to such products or services. If we and our affiliated companies have separate privacy policies for the products or services they provide to you, the corresponding products or services shall be subject to the corresponding privacy policies.

In particular, this policy does not apply to services provided to you by other third parties.

The policy was last updated on June 25 , 2025

Please read this policy carefully and thoroughly before using LegionSpace application, especially the clauses marked with bold/bold underline. You should read them carefully and start using them after confirming their full understanding and agreement. This policy has the effect of contract. Please read it carefully and follow it. If you have any questions, comments or suggestions about the content of this policy, you can contact us through the various contact methods provided by the LegionSpace application.

This policy will help you understand the following:

1、 Scope of application and meaning of Related words in this "LegionSpace application privacy protection policy"

2、 How do we collect and use your personal information

3、 How do we use cookies

4、 Provide prominent statements on how personal information and sensitive data are shared, assigned, transferred, publicly disclosed

5、 How do we protect your personal information

6、 Your rights

7、 Protection of minors' information

8、 Update of this “LegionSpace application privacy protection policy”

9、 How to contact us

10、 Others

1、Scope of application and meaning of Related words in this "LegionSpace application Privacy Protection Policy"

（1） Scope of LegionSpace application Privacy Protection Policy

This policy is applicable to all our products and/or services. When you use any of our products and/or services, this policy applies regardless of whether the product and/or service has separate privacy provisions, and whether you are a browsing user (Visitor) or a registered login user. Please note that this policy does not apply to the following situations:

1) Information collection/processing practices of third parties providing advertising services for our products and/or services;

2) Our products and/or services may contain or link to the information and/or third party services provided by the third party (including any third party applications, websites, products, services, etc.), which are operated by third parties, and you are not concerned with the use of such information and/or services. We hereby kindly remind you that when using third-party information and/or services, you should pay attention to and carefully read the relevant user agreement and privacy policy displayed to you by the third party, and keep and provide your personal information carefully. This policy only applies to your personal information collected by us. It does not apply to the collection of your personal information by any third party, the services provided by any third party or the information use rules of the third party. We do not assume any responsibility for the collection, storage and use of your personal information by any third party to the extent permitted by law

3) When you reach a cooperation intention with the service workers/service providers on the LegionSpace application, entrust the service workers/service providers to provide any services or provide any service results, the information you voluntarily provide to the service workers/service providers for the purpose of transaction is irrelevant to us. We hereby sincerely remind you that when you provide information to service workers/service providers, you should be reasonably vigilant and carefully provide your personal information;

4) Products and/or services provided to you by other non payment shield applications.

5) To ensure your normal use of our services, maintain the normal operation of our services, ensure the security of your use of our products, and improve and optimize your service experience, we will collect your device model, operating system, system version, network type, IMEI, MAC address, AndroidID, installed application list , APP crash record, traffic statistics, operation log Audio and video quality data (volume, video and audio packet loss rate, audio and video quality data are not related to your call content), function use records;

（2） Meaning of Related words

1) Our products and/or services: including but not limited to the software, websites, services and related product or service functions provided by us. What we need to remind you in particular is: as the types of your personal information collected by us may vary depending on the specific products and services you use, and the products and service contents provided to you are also different. This policy is a general privacy clause uniformly applicable to LegionSpace application. The user rights agreed in this policy and the relevant information security protection measures provided by us are applicable to all our products and services; Our products and/or services/services (including client type, software version, etc.) mentioned in this policy are different, which shall be subject to the actual situation of the products/services you actually use. For some of our specific products/services, we will also develop specific privacy policies to clarify our privacy rules and protection measures to you more specifically.

2) Personal information (derived from GB/T 35273-2020 "information security technology specification for personal information security"): refers to all kinds of information recorded by electronic or other means that can identify the identity of a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information. The personal information involved in this privacy policy includes personal basic data (including personal name, birthday, gender, address, personal telephone number, e-mail), identity information (including ID card information, enterprise business license information), personal biometric information (facial features), network identity information (including system account, IP address, email address, and The password, password, password protection answer, user's personal digital certificate), personal property information (including bank account number, identification information (password), fund information (including fund quantity, income and balance), transaction and consumption records, running records, virtual currency (such as consumption balance and coupon), virtual transaction, exchange code and other virtual property information) , address book information, personal online records (including website browsing records, software usage records, click records), personal common equipment information (including hardware serial number, hardware model, device MAC address, operating system type, installed application list , unique device identification code (such as IMEI/Android ID/IDFA/openudid/guid, SIM card IMSI information, etc.) describing personal common equipment Information of the situation), personal location information (including general geographic location, precise positioning information). The types of personal information we actually collect are as described below.

3) Personal sensitive information (derived from GB/T 35273-2020 information security technology personal information security specification): refers to personal information that, once disclosed, illegally provided or abused, may endanger personal and property safety and easily lead to personal reputation, physical and mental health damage or discriminatory treatment. The personal sensitive information involved in this privacy policy includes your property information (including bank account number, identification information (password), capital information (including fund quantity, income and balance), transaction and consumption records, running records, virtual currency (such as consumption balance and preferential coupon), virtual transaction, exchange code virtual property information), and personal biometric information (including bank account number, identification information (password), capital information (including fund quantity, income and balance), transaction and consumption record, flow record, virtual currency (such as consumption balance and preferential coupon), virtual transaction, exchange code virtual property information), and personal biometric information Department characteristics), personal identity information (including ID card information), network identity information (including system account number, email address and password, password, password protection answer, user's personal digital certificate) and other information (including address book information, personal telephone number, accurate positioning information, receiving address, web browsing record). You agree that your personal sensitive information will be processed in the purpose and manner described in this policy. The types of personal sensitive information we actually collect are subject to the description below. Compared with other personal information, personal sensitive information may have a greater impact on your personal rights and interests. We kindly remind you to consider carefully before providing us with your personal sensitive information.

4) Dematerialization: refers to the technical processing of personal information, so that the subject of personal information cannot be identified, and the processed information cannot be restored.

5) Delete: refers to the behavior of removing personal information from the system involved in the realization of daily business functions, so that it can not be retrieved and accessed.

6) LegionSpace application: refers to LegionSpace website（“ https://LegionSpace.tongfudun.com ”）And LegionSpace application client.

7) Affiliated company: refers to the company or organization that controls, is controlled by, or under common control with Jiangsu PayEgis Technology Co., Ltd. at present and in the future. Control refers to the ability to directly or indirectly influence the management/operation of the controlled object through ownership, voting shares, contract, actual operation connection or other legally recognized ways.

The basic information of our main operating company is as follows: Jiangsu PayEgis Technology Co., Ltd., established on December 9, 2013, with its registered address at 4f, building C2, Suzhou 2.5 Industrial Park, No. 88, Dongchang Road, Suzhou Industrial Park, Suzhou area, Jiangsu pilot free trade zone

Common office address: 4f, building C2, Suzhou 2.5 Industrial Park, No. 88, Dongchang Road, Suzhou Industrial Park, Suzhou pilot Free Trade Zone, Jiangsu. Contact number: 400-831-8116. If you want to know more about our company and platform, you can contact us through the contact information provided in this policy.

2、 How do we collect and use your personal information

We collect information to better, more efficiently, and more accurately provide the services you choose. We collect information in the following ways:

（1） The information we collect and use

1) When installing the LegionSpace app, to ensure the security of your account, we will collect and use your device model, operating system, device identifiers (IMEI, IDFA, IDFV), Android ID,International Mobile User Identity (IMSI), MAC address, Bluetooth address, intranet IP, WLAN access point (such as SSID, BSSID), latitude and longitude information, device basic information (model, storage, battery level, brightness), system basic information (system version, language, time zone), application installation list, network access method, type and status (such as SSID and BSSID), network quality data, device accelerator (such as gravity sensing devices), operation logs, service log information (such as when you search and view operations in LegionSpace). Log information such as records, service failure information, referral websites, etc. At the same time, in order to prevent viruses, Trojan programs, or other malicious programs and websites, we may collect installation and uninstallation information of your device's applications, running process information, or memory data to prevent the leakage of your personal information.

2) When you register as a user of the LegionSpace or use the LegionSpace service, you need to provide us with at least your personal mobile phone number (or email, contact phone, fax number, contact address, account internal message) and the password you plan to use. We will verify your identity by sending a SMS verification code (which may be notified to one or more of them, such as email registration). You should be aware that the matching results of your mobile phone number and verification code belong to your personal sensitive information. We collect such information to meet relevant legal and regulatory requirements. If you refuse to provide it, it may result in you being unable to use this function. Please consider carefully before providing it. Your account name is the default nickname you provided. You can enter the account settings to modify and supplement your nickname, avatar, and bound phone, all of which belong to your "account information". To ensure transaction recognition, your nickname and avatar will be publicly displayed.

2) You can provide us with corresponding identity information (ID card, business license) and biometric features (static or dynamic facial features) according to the authentication requirements to complete real name authentication.

3) When registering for LegionSpace, you can also provide one or more of your contact information (email, contact phone, fax number, contact address, account internal message). In our operations, we may send multiple types of notifications to one or more of them for user message notifications, identity verification, security verification, and other purposes. In order to deliver the information to you in the first time, even when you have not actively opened the application temporarily, we need to request "auto start" permission. This is not an arbitrary occupation of resources, we will provide you with permission to use it.

4) When you use the LegionSpace App service, in order to ensure your normal use of our service, maintain the normal operation of our service, improve and optimize our service experience, and ensure the security of your account, we will collect and use your device model, operating system, device identifier (Android version such as AndroidID/OAID, iOS version such as IDFA before iOS14.5), login IP address, MAC address, WeChat software version number, network access method, type and status (such as SSID and BSSID), network quality data, device accelerator (such as gravity sensing device), operation log, service log information (such as your search and view of operation records in LegionSpace, service failure information, referral website information, etc.) and other logs. Information. At the same time, in order to prevent viruses, Trojan programs, or other malicious programs and websites, we may collect installation and uninstallation information of your device's applications, running process information, or memory data to prevent the leakage of your personal information.

5) When you recharge, purchase, or place orders in LegionSpace, we will collect your recharge order information and usage records, which are necessary to provide you with this feature.

6) When using the search function in LegionSpace, in order to provide you with more accurate location related search services, we will collect your location information after obtaining your autonomous consent. Refusing to provide this information may prevent you from using the above functions or achieving the intended effects of the location-based services provided above, but it does not affect your normal use of other functions of the large group space. At the same time, in order to show you more accurately matched search service content, we will collect and use your search records, automatically analyze the above information through computer programs, predict your preference characteristics, and provide services that may be more in line with your interests.

7) When you use LegionSpace voice input, voice to text conversion, search for chat content (including text information and images), and search for chat images, we will collect your voice content, voice or text information to be converted, information to be searched, and search terms (excluding images) in the search chat image function, which are necessary to achieve the above functions. After real-time processing, we will return the processing results to you and will not save your data.

8) When you use the functions of posting updates, posting requirements, posting services or cases, real name authentication, and scanning services, we will need to obtain your camera/camcorder permissions and collect the graphic, textual, and video content information (personal information) you provide. If you refuse to provide, it will only prevent you from using the feature, but it will not affect your normal use of other features of the product and/or service.

9) When you use the feature of changing avatars, posting updates/comments, and uploading problematic images for feedback in the LegionSpace service, we will need to obtain your album permission, which you can manage through the device settings page. By granting this permission, you authorize us to access, obtain, collect, and use your personal information; After you cancel the authorization, we will no longer collect this information and will no longer be able to provide you with the corresponding services mentioned above; But unless you delete your personal information in accordance with legal provisions, your cancellation will not affect our processing and storage of personal information based on your previous authorization.

（2） Obtaining your personal information from third parties

When you use the functions or services of the Chain App, in certain specific usage scenarios, our bank may use a software service toolkit ("SDK" for short) provided by a third-party service provider with corresponding business qualifications and capabilities. To provide you with services, the third-party service provider needs to collect your necessary information. At the same time, it also clearly discloses the specific application scenarios of each SDK.

SDK name	Collecting information	Thoroughfare	Scenes	Receiver
Xiaomi Push SDK	Device identification OAID and encrypted Android ID, IDFV, application package name, version number and running status, device manufacturer, device model, device memory, operating system version, Xiaomi Push SDK version, device attribution (country or region), SIM card Carrier name, current network type,installed application list, MAC address,WLAN access point (such as SSID, BSSID) , Application starts automatically	Ensure Xiaomi device users receive message notifications normally	App push service	Xiaomi Technology Co., Ltd.
Meizu Push SDK	Mobile terminal unique identification information (IMEI number), mobile phone model, system type, system version, network type, installed application list , MAC address, operator information, WLAN access point (such as SSID, BSSID)	Ensure Meizu device users receive message notifications normally	App push service	Meizu Communication Equipment Co., Ltd.
Huawei Push SDK	Mobile terminal unique identification information (IMEI number), running programs, Mac address,WLAN access point (such as SSID, BSSID)	Ensure Huawei device users receive message notifications normally	App push service	Huawei Device Co., Ltd. and its affiliates
Vivo Push SDK	External storage permissions, running programs	Ensure V i vo device users receive message notifications normally	App push service	Vivo Mobile Communication Co., Ltd.
Oppo Push SDK	External storage permissions	Ensure Oppo device users receive message notifications normally	App push service	Guangdong Huantai Technology Co., Ltd.
WeChat sharing SDK	None	Users share content on the LegionSpace to WeChat	WeChat sharing	Tencent Computer System Co., Ltd. and its affiliates
WeChat payment SDK	None	Ensure that users support WeChat payment methods when using the service	WeChat payment	Tencent Computer System Co., Ltd. and its affiliates
WeChat Login SDK	Obtain the account information (avatar, nickname, region, gender) that you authorize to share from WeChat	Use WeChat to log in to the LegionSpace	ntegrated WeChat account login function	Tencent Computer System Co., Ltd. and its affiliates
WeiB o SDK	Mobile terminal unique identification information (IMEI number)	Users share content on the LegionSpace to the Weibo platform	One-click sharing function	Beijing Weimeng Chuangke Network Technology Co., Ltd.
Payegis SDK	Mobile terminal unique identifier (IMEI, IDFA, IDFV), International Mobile Subscriber Identity (IMSI), MAC address, Android ID, Bluetooth address, intranet IP, WLAN access point (such as SSID, BSSID), latitude and longitude information, basic device information (model, storage, power, brightness) , system basic information (system version, language, time zone), installed application list	Scan the application installation list of user devices to check for unsafe applications and protect user account security	Risk control function	J iangsu Tongfudun Information Security Technology Co., Ltd.
Alipay SDK	Device MAC address, Android ID, device IMEI, location information, installed application list , phone number, WLAN access point (such as SSID, BSSID), IMSI, sensor, device name, IP address	Support users to use Alipay to pay on the chain	Payment function	Alipay (China) Network Technology Co., Ltd.
Umeng U-Share Social Sharing SDK	Device identification information is used to generate a desensitized end-user device identification and complete information sharing services to the device, including: Required: AndroidID/OAID/IDFA/IDFV/0penUDID/CUID Optional: IMEI/IMSI/IOCID	Users share LegionSpace content to some social platforms	Content sharing	Umeng Tongxin (Beijing) Technology Co., Ltd.
ZXing QR code scanning SDK	None	Scan the QR code to add friends on the chain	QR code scannin g	None

For example:

1) When you use the payment function in the application, Alipay, WeChat and other related SDK will collect your device information (equipment type, device settings, unique device identifier, etc.), to ensure that you complete the payment function in a secure trading environment.

2) When you watch services, cases and other videos in the app, the relevant SDK will collect your device information to ensure the normal play of the video.

3) When you upload your avatar and publish dynamic/service/case images, the relevant SDK will collect your device information and the image files on the SD card to ensure the normal uploading of pictures.

4) After obtaining your location authorization, the relevant SDK will collect your device information, operator information and geographic location information. We will provide you with nearby services, service providers and preferential information based on your location information.

5) When you use Huawei/Xiaomi mobile phone/other Android phones, the relevant SDK will collect your device information for your mobile phone to receive push notification.

6) When you perform real-name authentication through face recognition, the relevant SDK will collect the front and back of your ID card and face video to perform ID card recognition, face recognition and liveness inspection to complete real-name authentication through face recognition.

7) During the application process, in order to conduct data statistics and analysis, the relevant SDK needs to collect your device information (device brand, model, software version, etc.), network information, location information and application information.

（3） How we use your personal information

In order to comply with national laws, regulations, and regulatory requirements, as well as to provide you with services, improve service quality, or safeguard your account security, LegionSpace will use your information under the following circumstances：

1) The LegionSpace will use the personal information collected from you in accordance with the provisions of this policy and to achieve the services or functions of the LegionSpace.

2) To keep you informed about the status of the LegionSpace App service, we will send you service notifications. You can turn off service notifications in the notification settings of your mobile phone system, or you can turn them back on in the notification settings.

3) To ensure service stability and security, LegionSpace will use your information for identity verification, security protection, fraud monitoring, preventing or prohibiting illegal activities, risk reduction, archiving, and backup purposes.

4) According to laws, regulations, or regulatory requirements, report to the relevant departments.

5) After collecting your personal information, LegionSpace will anonymize your data through technical means. Once anonymized, the information can no longer identify the subject and may be used directly without your consent. They reserve the right to analyze user databases and utilize them for commercial purposes.

6) LegionSpace will conduct statistics on the usage of the App's services or features to demonstrate the overall usage trends of the services or features in LegionSpace. However, these statistics do not contain any of your personally identifiable information.

7) When LegionSpace displays your information, methods such as content replacement and anonymization will be used to desensitize your information in order to protect your data security.

（4） Exceptions to obtaining authorization and consent

According to relevant laws, regulations, regulatory requirements, and national standards, under the following circumstances, LegionSpace will process your personal information without seeking your authorization or consent:

1) Directly related to national security and defense security;

2) directly related to public safety, public health, and major public interests

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

4) For the necessity of safeguarding your or other individuals' life or property safety

5) The personal information processed is that which you have voluntarily disclosed or that which has otherwise been lawfully made public.

6) Necessary to fulfill the statutory duties or obligations of LegionSpace

7) Necessary for maintaining the secure and stable operation of the provided products or services, such as detecting and addressing faults in the products or services.

8) Other circumstances required by laws, regulations and regulatory provisions

3、How do we use Cookies

(1) In order to achieve the personalized needs of your experience, so that you get a better experience. We will send one or more small data files called cookies on your computer or mobile device, which can only be read by publishing cookies to web servers in your domain. We send cookies to you in order to simplify the steps of your repeated login, store your browsing preferences and other data, and then provide you with preference selection, help judge your login status and account or data security.

(2) We will not use cookies for any purpose other than those stated in this privacy policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on the computer. Most web browsers will automatically accept cookies, but you can usually modify the settings of your browser to reject cookies according to your own needs. In addition, you can also clear all cookies saved in the software. However, if you do so, you may need to change the user settings personally every time you visit the website, and the corresponding information you have recorded before will be deleted, which may have a certain impact on the security of the service you use.

4、Provide prominent statements on how personal information and sensitive data are shared, assigned, transferred, publicly disclosed

1) Information sharing

We will not share your personal information with companies, organizations and individuals other than LegionSpace

, except for the following situations:

(1) Sharing under legal circumstances: we may share your personal information with the public in accordance with laws and regulations, the needs of litigation and dispute resolution or the requirements put forward by administrative and judicial organs according to law;

(2) Sharing with explicit consent: after obtaining your explicit consent, we will share your personal information with other parties;

(3) Sharing with related companies: in order to facilitate us to provide products and services to you based on the application of LegionSpace , recommend the information you may be interested in, identify abnormal member accounts, and protect the personal and property safety of LegionSpace 's affiliated companies or other users or the public from infringement, your personal information may be shared with our affiliated companies and/or their designated service providers. We will only share the necessary personal information and be bound by the purpose stated in this privacy policy. If we share your personal sensitive information or the affiliated company changes the use or processing purpose of personal information, we will seek your authorization again.

(4) Sharing with authorized partners: we may entrust authorized partners to provide you with certain services or perform functions on our behalf. We will only share your information for the legitimate, legitimate, necessary, specific and explicit purposes stated in this privacy policy. Authorized partners can only access the information they need to perform their duties and shall not use this information for any other purpose.

Our authorized partners include the following types:

a. Partners/enterprises/institutions providing a certain service together with us: in order to Pal your needs and realize business processing, we need to provide your name, contact information, identity information and company information to the organizations (including banks, government agencies, government parks) that have business reporting and auditing, and enterprise service outsourcing (registration, service and human resources).

b. Third party SDK service providers: we send information to partners who support our business, including technical infrastructure services and analysis entrusted by us.

How we use our services, measure the effectiveness of our services, provide customer service, facilitate payment, or conduct academic research and research. In order to enable you to use the above services and functions, our application will embed the authorized partner's SDK or other similar applications. For example:

2) When you watch services, cases and other videos in the app, the relevant SDK will collect your device information to ensure the normal play of the video.

5) When you use Huawei/Xiaomi mobile phone/other Android phones, the relevant SDK will collect your device information for your mobile phone to receive push notification.

6) During the application process, in order to conduct data statistics and analysis, the relevant SDK needs to collect your device information (device brand, model, software version, etc.), network information, location information and application information.

7) When you are using an application, in order to collect app crash information, the relevant SDK needs to collect your device information to help us repair the application crash and other issues.

8) The information collected and processed by the above-mentioned service providers will not be stored in the LegionSpace . The behaviors of the service providers comply with their own privacy provisions, which are not applicable to this policy. However, we will also strive to review the business access qualification of the third party and strive to require the legality, compliance and security of such service providers. In order to ensure your information security to the maximum extent, we strongly recommend that you check the privacy terms of any third-party SDK services before using them. In order to protect your legitimate rights and interests, if you find that there are risks in such SDK or other similar applications, we suggest that you immediately terminate the relevant operations and contact us in a timely manner.

( 5 ) It is shared according to the relevant agreements (e.g. online agreement, platform rules, etc.) or legal documents signed by you and us;

( 6 ) In some cases, only by sharing your personal information can we realize the core functions of our products and/or services, provide the services you need, or handle disputes or disputes between you and others;

( 7 ) In order to protect the legitimate rights and interests of users of general payment shield and/or other general payment shield applications;

2) Transfer of information

We will not transfer your personal information to any company, organization or individual except:

(1) Transfer with explicit consent: after obtaining your explicit consent, we will transfer your personal information to other parties;

(2) In the case of merger, acquisition or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new company or organization holding your personal information to continue to be bound by this personal information protection strategy; otherwise, we will require the company or organization to seek authorization from you again.

3) How your information is transferred globally

Personal information collected and generated by our operations in the people's Republic of China is stored in China. Exceptions are as follows:

(1) The applicable law has clear provisions.

(2) Obtain your explicit authorization.

In the above circumstances, we will ensure that your personal information is adequately protected in accordance with this privacy policy.

4) Public disclosure

We will only disclose your personal information in the following circumstances：

(1) With your explicit consent.

(2) Disclosure based on Law: we may disclose your personal information publicly without further notice to you under the circumstances of laws, legal procedures, litigation or mandatory requirements of government authorities.

(3) Disclosure based on the application of other platform users or any third party and providing preliminary evidence: when you have a legal dispute with other users of the platform, or any third party thinks that your behavior infringes on their legitimate rights and interests and intends to file a legal action, after the applicant provides the basic evidence, we may disclose your personal information publicly, and we will retain the applicant's disclosure Record, so that you can inquire about the disclosure of your personal information at any time.

5) Exception of prior authorization for sharing, transferring and public disclosure of personal information

In the following circumstances, your authorization and consent are not required to share, transfer and publicly disclose your personal information:

(1) Directly related to national security and national defense security.

(2) Directly related to public safety, public health and major public interests

(3) Directly related to criminal investigation, prosecution, trial and execution of judgments; or according to the requirements of laws and regulations, administrative organs or public security organs, etc.

(4) In order to protect your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain your own consent.

(5) Personal information that you disclose to the public by yourself.

(6) Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels.

Please be aware that according to applicable laws, if we take technical measures and other necessary measures to process personal information, so that the data receiver can not re identify specific individuals and cannot be recovered, the sharing, transfer and public disclosure of such processed data need not be further informed and agreed by you.

(6) Provide prominent statements on how personal information and sensitive data are shared, assigned, transferred, publicly disclosed

For example:

2) When you watch services, cases and other videos in the app, the relevant SDK will collect your device information to ensure the normal play of the video.

5) When you use Huawei/Xiaomi mobile phone/other Android phones, the relevant SDK will collect your device information for your mobile phone to receive push notification.

5、How do we protect your personal information

1) In order to ensure your information security, LegionSpace takes various reasonable physical, electronic and management security measures to protect your information, so that your information will not be leaked, damaged or lost, including but not limited to SSL, information encryption storage, access control of data center, dedicated network channel and agent, blockchain technology. LegionSpace also takes strict management on employees or outsourcing personnel who may have access to your information, including but not limited to taking different authority control according to different positions, signing confidentiality statement with them, and monitoring their operation.

LegionSpace will provide corresponding security measures according to the existing technology to protect your information and provide reasonable security guarantee. LegionSpace will try its best to prevent your information from being leaked, damaged or lost at any time.

Your information is stored on the server in China. For security and backup needs, LegionSpace may store your information and data on the server of LegionSpace 's company with corresponding security measures. We will take reasonable and feasible measures to avoid collecting irrelevant personal information. We will only retain your personal information for the period required to achieve the purpose stated in the cost policy, unless there is a mandatory retention requirement by law. For example, the "e-commerce law of the people's Republic of China" requires that commodity and service information and transaction information be kept for at least three years from the date of completion of the transaction.

2) We have set up an information security committee and established corresponding security management system and process security to ensure the security of information. For example: strictly limit the scope of personnel accessing information, sign confidentiality agreement for key positions, and conduct regular audit. In the event of personal information leakage and other security incidents, we will start the emergency plan to prevent the expansion of security incidents, and inform you in the form of announcement.

6、How do you manage your information

1) You can query, update and delete (part) your personal information

The platform provides you with the functions of personal information self-service query, update and deletion (part of) information, and the deletion function of some information needs to be realized by canceling your account. At the same time, you can also request the service of inquiry, update and deletion of relevant information through the official customer service hotline 400-831-8116.

(1) The personal information query, update and deletion paths are as follows:

a. Basic account information: mobile terminal can view and update through "Me - Personal Information", including nickname, avatar, mobile phone number, QR code and other information.

b. Account security information: mobile terminal can view and update through "Me-Security Center", including password, binding collection, binding mailbox, login protection settings, etc.

c. Real name information: mobile can view and update through "Me - Personal Information - my eID", including personal real name information.

d .Account cancellation: the mobile terminal can cancel the account through "Menu Bar - Security Center - Account Cancellation"

(2) Order information:

For service orders, the mobile terminal can view the order information through the "Me - My Points" page.

2) You can change the scope of authorization consent

If you want to change the authorization of relevant permissions, you can modify them through your hardware device or operate in the relevant function setting interface of our products or services.

3) You can apply to cancel the personal information subject account

You can apply to cancel your previously registered account at any time. You can log in to the cancellation application page to initiate the Cancellation Application, and your account will be canceled in three word days after the platform is approved. You can also request the customer service of LegionSpace application to provide account cancellation service through the official customer service hotline of LegionSpace application. If you cancel your account number, please properly handle the funds, invoices and in transit transactions in accordance with the relevant provisions of the application of general payment shield.

After the account is canceled, we will stop providing you with products and services, and delete your personal information according to your requirements, unless otherwise stipulated by laws and regulations.

4) Automatic decision making of constraint information system

In some business scenarios, we may only make decisions based on non manual automatic decision-making mechanisms including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will also provide appropriate remedies, unless otherwise stipulated by laws and regulations.

5) Respond to your above request

For security, you may need to provide a written request or other means to prove your identity. We may ask you to verify your identity before processing your request. In principle, we will not charge you for your reasonable request, but we will charge a certain cost for repeated requests beyond the reasonable limit. We may reject requests that are unreasonably repetitive, require excessive technical means (e.g., the need to develop new systems or radically change existing practices), pose a risk to the legitimate rights and interests of others, or are highly impractical (e.g., involving information stored on backup tapes).

We will not be able to respond to your request under the following circumstances:

a. Related to national security and national defense security.

b. Related to public safety, public health and major public interests.

c. Related to criminal investigation, prosecution and trial.

d. There is sufficient evidence of malicious abuse or subjective existence of your rights.

e. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations.

7、How do we protect minors' information

We attach importance to the protection of minors' personal information, and our products, websites and services are mainly for adults. In e-commerce activities, we presume that you have the corresponding civil capacity. If you are a minor, we ask your parents or other guardians to read this privacy policy carefully and use our services or provide information to us with the consent of your parents or other guardians.

If we recognize that you are a child user, we will inform your guardian and ask your guardian to agree to the rules for the collection and use of minors' personal information. If we fail to contact your guardian or your guardian does not agree with our rules on the collection and use of minors' personal information, we will try to delete the relevant data as soon as possible. We will only use, share, transfer or disclose children's personal information when using our products or services with the consent of parents or other guardians, as permitted by laws and regulations, explicitly agreed by parents or other guardians, or necessary to protect minors.

If you are the parent or other guardian of the child, please pay attention to whether the child in your custody uses our service after obtaining your authorization and consent. If you have any questions about the personal information of the child in your custody, please contact us through the contact information in Section 9.

8、Update of this LegionSpace application Privacy Protection Policy

LegionSpace may change this policy. Without your explicit consent, we will not reduce your rights under this privacy protection policy. In case of any change, LegionSpace will inform you in accordance with the notice provisions in the application service agreement of LegionSpace , and the change will take effect immediately after the expiration of the publicity period. If you continue to visit LegionSpace 's website and related websites, or mobile device clients, or use any service provided by LegionSpace after the change of this policy, you confirm that you have fully read, understood and accepted the revised policy and are bound by it.

9、Contact us

If you have any questions, opinions or suggestions about this personal information protection policy, you can contact us at any time through the following ways. Generally, we will reply within 15 days.

1. Visit www.tongfudun.com and contact us through online customer service system.

2. Call customer service: 400-831-8116, fax: 0512-67903886

3. Send email to: service@tongfudun.com.

4. Office address: Room 1101, Taiping Financial Building, Suzhou Industrial Park, Jiangsu Province.

If you are not satisfied with our reply, especially if our personal information processing behavior has damaged your legitimate rights and interests, you can also make a complaint or report to supervisory departments such as network information, telecommunications, public security and industry and commerce.

10、Others

You should carefully read and fully understand the meaning of all contents of this privacy protection policy (especially the bold font content) and the legal effect arising therefrom, and voluntarily agree to this policy. Once you click "agree" to this privacy protection policy online, it will be deemed that such behavior is your true intention, and you agree to bear all legal consequences arising therefrom.

This privacy protection policy is applicable to the laws of the people's Republic of China. In case of any dispute between you and LegionSpace based on this policy, both parties agree to submit the dispute to the court of Suzhou Industrial Park for settlement.

The legal language of this privacy policy is Chinese. In case of any inconsistency between the Chinese version and the English Version (translation version), the Chinese version shall prevail.