UniMgr Privacy Policy

Version: V3.0 | Published: 2026/10/13 | Effective: 2026/10/10

INTRODUCTION

QTHYCC ("we", "us" or "our") fully understands the importance of personal information to you and processes it with care. This UniMgr Privacy Policy (the "Policy") explains how we collect, use, store, share, transfer and protect your personal information when you register for and sign in to the UniMgr unified account and use our products, and how you can exercise your rights.

Please read this Policy carefully before using our services. Once you start using the services, you are deemed to have fully understood and agreed to this Policy. Provisions of particular importance to you are marked in bold.

1. Scope and Legal Basis

1.1 This Policy applies to the UniMgr unified account and all products accessible through that account (collectively, the "Services"). Individual products may issue product-specific privacy notices consistent with this Policy; absent specific provisions, this Policy prevails.

1.2 This Policy is formulated in accordance with the Personal Information Protection Law, Cybersecurity Law and Data Security Law of the People's Republic of China, and with reference to the principles of major data protection laws of other jurisdictions, such as the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act as amended (CCPA/CPRA), so as to provide users in different regions with an appropriate level of protection.

2. Information We Collect

2.1 Information you provide:

  • Account information: username, email address and password (stored encrypted) provided at registration;
  • Transaction information: orders, payment records, invoices or delivery details generated when you use paid services (where applicable);
  • Content you provide when contacting us, and identity-verification materials you submit when necessary.

2.2 Information collected automatically when you use the services:

  • Device and log information: device model, operating system, IP address, browser type, access time and records;
  • Usage data: feature usage, preference settings, crash and performance logs.

2.3 Third-party sources: With your authorisation, we may receive necessary information from payment providers, app stores and the like (such as payment results).

2.4 We do not actively collect sensitive personal information. Where collection is required by law or strictly necessary for the services, we will obtain your separate consent in advance or rely on other lawful bases prescribed by law.

3. How We Use Information

3.1 We use your information for the following purposes:

  • creating and managing the unified account and providing registration, sign-in and password recovery services;
  • providing features and services of the Products (such as memberships, entitlements, orders and customer support);
  • processing transactions, delivering virtual goods and providing after-sales and refund services;
  • safeguarding the services and account security, including risk identification and fraud prevention;
  • performing statutory obligations (such as identity verification, data retention and cooperation with authorities);
  • with your consent, sending you service notifications, product updates or marketing messages (you may unsubscribe at any time).

3.2 Withdrawal of consent: For processing based on your consent, you may withdraw it at any time; withdrawal does not affect the lawfulness of processing carried out before withdrawal. Withdrawal may render certain features unavailable.

3.3 Automated decision-making: We will not make automated decisions with legal or similarly significant effects on you (such as automatic bans) without providing a channel for human review. If you disagree with a risk-control decision, you may request human review via the contact details in Section 12.

4. Cookies and Similar Technologies

4.1 We and authorised third parties may use cookies, LocalStorage, SDKs and similar technologies to keep the services running, remember your preferences and analyse performance. For details, see the UniMgr Cookie Policy.

4.2 You can manage cookies via your browser or in-product settings; rejecting certain cookies may affect functionality.

5. Sharing, Transfer and Public Disclosure

5.1 Sharing: We share your personal information only for the purposes stated in this Policy, on a minimum-necessary basis, with the following categories of recipients:

  • the Products: to enable unified sign-in and account services, we share necessary basic Account information (such as username, membership and entitlement status);
  • payment and settlement providers: to process payments and refunds;
  • cloud and infrastructure providers: to provide storage, computing and network support;
  • judicial and administrative authorities, where we are legally required to cooperate.

5.2 Beyond the above, we will not share your personal information with any third party; where sharing is genuinely necessary, we will seek your separate consent.

5.3 Transfer: In the event of a merger, division, acquisition or asset transfer, we will require the successor to continue to be bound by this Policy; otherwise we will require it to obtain your consent again.

5.4 Public disclosure: We do not publicly disclose your personal information in principle, except where required by law or with your consent.

6. Cross-Border Data Transfers

6.1 Personal information collected in the course of our operations in mainland China is, in principle, stored within China. Where cross-border transfer is genuinely necessary (e.g. use of overseas cloud services or CDNs, or access from abroad), we will comply with the Personal Information Protection Law and the laws of the destination country/region, adopting lawful pathways such as security assessment, standard contracts or certification, together with safeguards such as encryption and de-identification.

6.2 For services provided to users in the EU/EEA and the UK, cross-border transfers of personal data, where they occur, are made under appropriate GDPR safeguards (such as Standard Contractual Clauses).

7. Retention and Location

7.1 Storage location: see Section 6. We retain your personal information only for the shortest time necessary to achieve the purposes of this Policy; thereafter we delete or anonymise it.

7.2 Statutory retention: records required by law (such as transaction records and logs) are retained for the statutory period.

8. Data Security

8.1 We adopt industry-standard technical and organisational measures to protect your personal information, including encryption in transit (TLS), salted password hashing, access control and least privilege, security auditing, data backup and emergency response plans.

8.2 Security incidents: In the event of a personal information breach, we will promptly activate emergency plans, contain the incident, and inform you by push notification, public announcement or email of the incident, its possible harm, the remedial measures taken and the steps you can take, unless exemption from notification is provided by law.

8.3 Although we take reasonable measures, no internet environment is completely secure. Please safeguard your Account credentials and avoid staying signed in on public devices.

9. Your Rights

9.1 All users may: access, review, copy, correct, supplement and delete their personal information; withdraw consent; cancel their Account; request explanations; and lodge complaints and reports.

9.2 Mainland China users: You further enjoy the rights under Articles 15 and 44–50 of the Personal Information Protection Law, including the right to portability (where conditions are met), the right to explanation, and the right to complain to the competent authorities.

9.3 EU/UK users (GDPR/UK GDPR): Within the applicable scope, you have the rights of access, rectification, erasure ("right to be forgotten"), restriction of processing, data portability, and objection (including absolute objection to direct marketing and to processing based on legitimate interests), as well as the right to lodge a complaint with your local supervisory authority. Our legal bases for processing include: contract performance (account and orders), legitimate interests (security and anti-fraud), legal obligations (retention and cooperation with authorities), and consent (marketing and optional cookies).

9.4 California residents (CCPA/CPRA): You have the rights to know, to delete, to correct, to opt out of "sale or sharing" (we do not sell your personal information, nor do we use it for cross-context behavioural advertising), and to non-discrimination for exercising your rights. We do not process your sensitive personal information beyond what is necessary to provide the services.

9.5 Other regions: For users in Brazil (LGPD), Japan (APPI), Singapore (PDPA), South Korea (PIPA) and other jurisdictions, we will, to the extent feasible, safeguard your rights to be informed, to access, to correct, to delete and to withdraw consent at a level comparable to this section, and comply with mandatory local requirements.

9.6 How to exercise: See Section 12. After verifying your identity, we will respond promptly, generally within 15 business days (or the period required by applicable law). For manifestly unfounded or excessive repeated requests, we may lawfully refuse or charge a reasonable cost-based fee.

10. Protection of Minors

10.1 Our services are primarily intended for adults. We do not actively collect personal information from minors.

10.2 Minors under the age of fourteen in mainland China, and children below the statutory minimum age in other countries/regions, should use the Platform only with the consent and guidance of their guardians. For procedures by which guardians exercise rights on behalf of minors, see the UniMgr Minors Protection Policy.

10.3 If you are a guardian and discover that a minor has provided us with personal information without your consent, you may contact us to have it deleted.

11. Policy Updates

11.1 This Policy may be updated from time to time. For material changes (such as changes to collection purposes, processing methods or sharing scope), we will notify you prominently via pop-up, announcement or email and, where necessary, seek your consent again.

11.2 The version number and update date are shown at the top of this page; you can also review key points of previous versions via the Account Centre.

12. How to Contact Us

If you have any questions, comments or complaints about our processing of personal information, please contact us via the above channels and we will respond within 15 business days. If you are not satisfied with the outcome, you may, in accordance with the laws of your country/region, lodge a complaint with the relevant supervisory authority or seek judicial remedies.