Privacy Policy

中文 | English
Latest Version Release Date: December 19, 2025
Latest Version Effective Date: December 19, 2025

1. General

  1. 1.1 At viviTalk, we care about your personal data. We prepared this Privacy Policy to explain how we collect, use, and share such data.
  2. 1.2 This Privacy Policy (the "Privacy Policy") describes in detail the personal data Beijing Yunshang Qulv Technology Co., Ltd. and its affiliates ("viviTalk", "we", "us", or "our") receive about you, how we process such data, and your rights and obligations relating to personal data.
  3. 1.3 By using or accessing the Service, you agree to the terms of this Privacy Policy. Capitalized terms not defined herein have the meanings set forth in the www.vivitalk.net/terms Terms of Service. We may update this Privacy Policy to reflect changes in our information practices. If changes are material, we will post a notice on our website at least seven (7) days before the changes take effect and indicate the date of the last revision at the bottom of this Privacy Policy. Any revisions take effect seven (7) days after the website notice is posted.
  4. 1.4 If you are an employee, worker, or contractor of viviTalk, details on how we handle your personal information can be found in viviTalk's internal knowledge base. For employees based in Europe, we are committed to cooperating with EU data protection authorities ("DPAs") and to complying with their guidance regarding the transfer of human resources data from the EU in the context of employment relationships.
  5. 1.5 Mainland China: If you use or access viviTalk services directed to the People's Republic of China ("Mainland China", excluding Hong Kong, Macau, and Taiwan for purposes of this Privacy Policy), please visit our Mainland China page for your rights and other information applicable to you.

2. Information We Collect

  1. [Important Notice: Sensitive Personal Information]
  2. To provide relevant features, we may process the following sensitive personal information to the extent necessary:
  3. (1) Voice/Audio information (for speech recognition and speaking instruction);
  4. (2) Personal information of children under 14 (which requires additional protection under law);
  5. (3) Payment-related information (to process purchases).
  6. We process the above information only to the extent necessary to provide the relevant features and will highlight the processing purpose and method in bold wherever sensitive personal information is involved.
  7. This Privacy Policy explains how we collect, use, and share your personal data.
  8. 2.1 Information You Provide
    1. During registration, you will provide your username, email address (or your parent's email address), age or date of birth, phone number, and password. If you choose to pay for viviTalk services, you will also provide your payment transaction information. Payment information is sensitive personal information and is used solely to complete the transaction.
  9. 2.2 Activity Data
    1. 1. When you use the Service, you submit information and content to your profile. We also generate data about your use of our Service, including educational activities you participate in, or messages you send or otherwise transmit to other users (collectively, "Activity Data"). We collect technical data about how you interact with the Service.
    2. 2. We collect only the personal information necessary to provide the Service (for example, the username and password needed for account registration) and do not collect non-essential personal information such as:
      • Real name
      • Profile photo
      • Address or personal profile bio
    3. 3. We collect the following data:
      • Clicks
      • Mouse trajectory
      • Scrolling
      • Typing
    4. 4. Technical specifications:
      • Browser
      • Device model
      • Operating system
      • Viewport size
      • Script errors
      • IP address
    5. 5. Browsing behavior:
      • Pages visited
      • Referral source
      • URL parameters
      • Session duration
    6. 6. Learning behavior:
      • Course progress
      • Answers
  10. 2.3 Use of the "Role-Play" Feature
    1. [Sensitive Personal Information Notice: This feature may involve processing audio information]
    2. You may use the Role-Play feature, which allows you to send text or audio to an AI chat partner in an open-ended conversation. Any data shared through this experience will be shared with our AI vendors; audio information sent through this feature is sensitive personal information and is used only for speech recognition and teaching-related purposes. Vendors may retain copies of your text or audio outputs at their discretion. Please do not input personal data.
  11. 2.4 Speaking Question Types
    1. Some question types require you to speak to the viviTalk app. To recognize your speech, your audio may be sent to third-party service providers such as Google. We may ask for your voice data to help improve our courses and product quality, but we will not link it to your identity information. If you do not allow us to use your voice information or we have not obtained permission, we will not use your audio information in this way. Any audio you agree to send to viviTalk is anonymized upon reaching our servers to ensure it cannot be tied back to you.
  12. 2.5 Product Research & Development
    1. 1. We may contact you to participate in product research activities, including surveys, interviews, and other feedback sessions. The information you provide will be used to test, improve, and develop our products. We will record videos, audio, and transcripts of this feedback along with any other contact information you provide, and we retain this data for two (2) years.
    2. 2. Please contact contact@vivitalk.net to:
      • Request more information about research activities you voluntarily join;
      • Opt out of being contacted for research activities;
      • Request a copy of research-related data you provided.

3. Cookies

  1. 1. Once you log in to the website, we collect your browser type and IP address (the unique address that identifies your computer on the Internet). When you use our mobile app, we collect your device type, device ID, and IP address.
  2. 2. We also use cookies to store certain information in your browser. Cookies are data stored on a user's computer that relate to user information. We use session ID cookies to confirm that a user is logged in. If you do not want information collected via cookies, most browsers allow you to decline or accept cookies; however, cookies may be necessary for certain features (for example, personalized information delivery).
  3. 3. For more details about cookies and how to manage them, visit http://www.allaboutcookies.org.

4. How viviTalk Uses the Information We Collect

  1. 1. viviTalk may send you service-related notifications and product change notices as part of the general operation of the Service. We send reminder notifications to reinforce your learning rhythm, support the viviTalk teaching method, and help you stay engaged. We process your data to provide the Service, deliver personalized features, understand and improve our Service, and keep it safe and secure.
  2. 2. viviTalk may use or share anonymized data collected through the Service, including Activity Data, without restriction. Fulfilling our contract with you by providing the best possible Service is essential to us, and it is in our legitimate interests to carry out these processing activities and enable service emails by default to protect your data and deliver our Service. You may opt out of non-essential service emails at any time.
  3. 3. We may use your contact information to send you details about new viviTalk services, offers, and promotions, provided that you have explicitly consented to receive such communications.
  4. 4. When you access the Service, viviTalk returns profile information for you to edit and may display profile information to other users. In some cases, other users can supplement your profile, including by submitting comments (which you can delete). We use this information to support you, send important notices, enforce our terms, conditions, and policies, communicate with you, administer the Service, and conduct internal operations such as troubleshooting, data analysis, testing, research, statistics, and surveys. The Terms of Service provide the contractual legal basis for these processing activities.

5. Sharing Your Personal Data with Third Parties

  1. 1. viviTalk shares your personal data only when necessary to provide the Service, when required by law, or when permitted by you.
  2. 2. We provide personal data to hosting providers, search engine providers, analytics providers, and support providers.
  3. 3. These data processors help us deliver the Service. For example, we may share your information to detect where or how you encountered errors when using our mobile app. For these operations, service providers may access personal data for a limited time. When we engage service providers to process personal data, we implement contractual safeguards that restrict their use of such personal data to providing services to viviTalk.
  4. 4. In response to lawful requests (such as subpoenas or court orders) or to comply with applicable law, we may be required to grant access to and disclose personal data. We may also grant access to and share account or other personal data when necessary to comply with the law, protect our interests or property, prevent fraud or other illegal activity conducted through the Service or using the viviTalk name, or prevent imminent harm. This may include sharing personal data with other companies, lawyers, agents, or government authorities.
  5. 5. If ownership of all or substantially all of viviTalk's business, or the ownership of business units or assets related to the Service, changes, your personal data will be transferred to the new owner. In any such transfer, your personal data remains subject to this section.
  6. 6. viviTalk shares aggregated or anonymized data collected through the Service, including Activity Data, for purposes such as understanding or improving the Service.

6. Data Subject Rights and Data Retention

  1. 1. You may manage your account settings in the personal center to update, modify, and correct your information.
  2. 2. Unless otherwise required by local law, you have the following rights with respect to the personal data we hold about you:
    • Request access to or deletion of your personal data;
    • Request that we restrict processing of your personal data;
    • Object to our processing of personal data about you;
    • If you have consented to our processing, withdraw that consent at any time;
    • Export the personal data you provided to viviTalk in a format that can be electronically transferred to a third party;
    • Delete your viviTalk account following the instructions provided in the Service.
  3. 3. viviTalk retains your data until your account is deleted. Afterward, we retain anonymized data collected through the Service, including Activity Data, which we may use or share with third parties.
  4. 4. Some rights are not absolute. In certain cases we may refuse a request if complying would prevent us from fulfilling our contractual obligations to provide specific products or services. When you make a request, we will inform you what actions we can take.
  5. 5. You also have the right to lodge a GDPR complaint with the relevant supervisory authority. A list is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, contact us using the information provided below and we will consider your request in accordance with applicable law. In some cases, our ability to uphold these rights may depend on our obligations to process personal information for security or anti-fraud reasons, to comply with regulatory or legal requirements, or because processing is necessary to provide the Service you request. In such cases, we will inform you of the specific details.

7. Third-Party Websites and Links

  1. 1. Third-party websites may place cookies on your computer to recommend our Service. Although we do not share your personal data with these third-party websites unless reasonably necessary to provide the Service, they may be able to link certain non-personally identifiable information we transmit to them with personal data they previously collected from you. Please review each website's privacy policy to understand its practices. viviTalk also reminds you that whenever you click links (including advertising banners) that lead to third-party websites, you will be subject to that third party's privacy policy.
  2. 2. Our Service contains links to other websites operated by third parties. viviTalk does not control those websites and is not responsible for their content, privacy policies, or use of personal data (including any personal or financial information collected by our third-party payment processors to process in-app purchases). The inclusion of such links on the viviTalk website does not imply any endorsement of their content or owners/operators, except as disclosed in the Service. Information you submit directly to third parties is governed by their privacy policies.

8. California Privacy Rights

  1. 1. California residents have the right to:
    • Know what personal information we collect about you and from where;
    • Access the personal information we maintain about you;
    • Understand how we process and share your personal information;
    • Opt out of sharing your personal information with certain third parties;
    • Request that we delete your viviTalk account and personal information.
  2. 2. To make such a request, email contact@vivitalk.net.

9. Children Under the Digital Age of Consent

  1. [Sensitive Personal Information Notice for Minors]
  2. We collect necessary personal information of children under 14 (sensitive personal information) and obtain guardian consent as required by law.
  3. 1. Children's privacy requires additional protection. We therefore treat child users differently so parents can control their experience, and we collect only the minimum information necessary for viviTalk to function.
  4. 2. Once a user creates a viviTalk account, we collect their age and compare it with local online child-consent standards based on the registration country. Users below that age are "Child Users." Child Users may create an account but must provide a parent's email address instead of their own. We do not allow Child Users to provide their own name because we do not require it.
  5. 3. After registration, we email the parent describing viviTalk's privacy and information practices for Child Users, including what personal data we collect and how we use, share, and protect it. The email also explains how parents can ask viviTalk to access, modify, or delete the child's relevant personal data.
  6. 4. Child Users are treated differently as follows:
    • "Mature" vocabulary such as "beer" or "wine" is removed from courses to keep content age-appropriate.
    • Ads are limited to family-safe content.
    • Profile pages are hidden to prevent disclosure of name, location, or bio.
    • Uploading profile photos is disabled.
    • Promotional emails are disabled.
    • Leaderboards are disabled.
    • Forums are disabled.
    • Child profiles are private and hidden from search.
    • Other users cannot follow the child.
    • Following or searching for other users is disabled.
    • Sending invitation emails is disabled.
    • Finding friends via Facebook is disabled.
    • Social logins via Facebook, Google, or Apple are disabled.
    • Social follow buttons for Twitter, Facebook, and Instagram are disabled.
  7. 5. Additionally, all users under 16 are treated differently as follows:
    • Ads are non-personalized.
    • Third-party behavioral tracking is disabled.
    • Third-party analytics are disabled.
  8. 6. To prevent restricted users from modifying these features, the relevant settings are hidden or shown as disabled (greyed out). Once a user reaches the required age, we automatically remove restrictions, reset settings to default, and make them visible so the user can configure them.
  9. 7. Pursuant to the Children's Online Privacy Protection Act ("COPPA"), viviTalk collects personal information from children under 13 only to operate the Service internally. If we learn that we unknowingly collected additional personal information from such children, we delete it. If you believe this has occurred, contact us at contact@vivitalk.net.

10. Links

  1. The Service may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to be aware when leaving the Service and to read the privacy statements of websites that collect personally identifiable information. This Privacy Policy applies only to information collected by viviTalk through the Service.

11. Information Security

  1. viviTalk implements administrative and technical safeguards it deems appropriate to protect your personal data. However, with sufficient resources, a determined attacker may defeat these protections and gain access to data we seek to protect.

12. Do Not Track

  1. The Service is not designed to respond to "Do Not Track" signals sent by certain browsers.

13. Contact Us

  1. Address: Room 02, 501, 5th Floor, Building 2, Yard 186, Beiyuan Road, Chaoyang District, Beijing, China
  2. Email: contact@vivitalk.net

14. Supplemental Privacy Policy for Mainland China

  1. This Supplemental Privacy Policy for Mainland China applies to use or access of viviTalk services directed to Mainland China. If there is any conflict or inconsistency between this Supplemental Privacy Policy and other provisions of the Privacy Policy, this Supplemental Privacy Policy prevails.

  2. 14.1 Data We Collect

    1. 1. We adhere to the principles of propriety, legality, and necessity. For the purposes described in this Supplemental Privacy Policy, we collect and use personal information that you actively provide or that is generated as a result of your use of viviTalk services. If we intend to use your personal information for other purposes not stated in this Privacy Policy (including this Supplemental Privacy Policy), or if we use information collected for a specific purpose for other purposes, we will notify you in a reasonable manner and obtain your consent again.
    2. 2. If you refuse to allow viviTalk to collect any of your personal information, we will be unable to provide functions beyond the "basic functions" of viviTalk services. In this case, viviTalk provides a "browse-only" mode, allowing you to view certain content without registering for a viviTalk account so you can decide whether to accept this Privacy Policy (including this Supplemental Privacy Policy).
    3. Registration Information
      1. 1. When you register as a viviTalk user, you must provide at least a mobile phone number to create an account. We verify your identity by sending an SMS verification code. After logging in, you may further improve your account information, including adding or modifying your email and username. Not providing such supplemental information does not affect your ability to use basic functions.
      2. 2. When you log in using a third-party account (WeChat, Apple ID), you may authorize viviTalk (as permitted by applicable laws and regulations) to read and obtain publicly available information registered, published, or recorded on that third-party platform (including nickname, avatar, and email).
    4. Speaking Question Types
      1. 1. Some question types require you to speak to the viviTalk app. To recognize your speech, your audio may be sent to third-party service providers such as Alibaba or Yunshang Qulv. We may ask you to use your voice data to help improve our courses and product quality. If you do not allow us to use your voice information or we have not obtained permission, we will not use your audio information in this way. Any audio you agree to send to viviTalk is anonymized upon reaching our servers.
      2. 2. When you use the Conversation Practice feature, viviTalk automatically receives and records relevant information based on your current language level, learning topics, preset content, the personality traits of dialogue characters, and the conversation content you voluntarily enter. We provide personalized speaking practice services by invoking the third-party large language model "Tongyi Qianwen" to generate conversation content for oral training. If you do not want us to collect and process the above personal information, please avoid entering such content; however, this may affect your ability to use the feature.
      3. 3. To provide a consistent experience and ensure service quality, we record the complete conversation history in the Scenario Dialogue feature, including the content you enter and topics generated from it. You may delete all account data via in-app path: Me -> Account -> Delete Account. To comply with applicable laws and cybersecurity obligations, we may retain your Q&A history and dialogue topics for the period permitted by law.
    5. Device Information
      1. When you access or use our services, we collect device information (such as screen resolution) for UI display, to prevent abnormal logins from other devices, and to retain necessary log information to ensure account, transaction, and system security. If you are not logged in, we use device information to display corresponding content. You can use basic functions only after consenting to this collection.
    6. Payment Function
      1. You may pay for certain viviTalk services. During payment, we may collect your third-party payment account information (such as Alipay, WeChat Pay, Apple Pay, or other bank card information).
    7. Customer Service
      1. When you file an appeal or consult viviTalk, we may need your name, phone number, and email address so we can contact you or help resolve the issue. Refusing to provide such information means you cannot file an appeal within the app, and we cannot provide timely feedback.
    8. Marketing Activities
      1. We may hold online or offline marketing activities, including invitations to offline events. We may require users to provide personal information (name and phone number) so we can contact them. Refusing to provide such information means you will not receive invitations. Where viviTalk needs to pay fees to you, we may collect identity information (name, phone number, email, and ID number) to withhold and pay taxes on your behalf. Without this information, we cannot issue invoices.
    9. User Interviews
      1. 1. To improve the viviTalk experience, we may conduct online or offline user interviews (for example, inviting users to online meetings) to understand issues encountered during use. We may screen candidates based on usage habits and location, then send SMS or other notices to ask whether you would like to participate.
      2. 2. We may require users to provide personal information (phone number) so we can contact them. Refusing to provide such information means you will not receive invitations. Where viviTalk needs to pay fees to you, we may collect identity information (name, phone number, email, and ID number) to withhold and pay taxes on your behalf. Without this information, we cannot issue invoices.
    10. Learning Reminders
      1. To improve the viviTalk experience, we may send learning reminders via SMS, push notifications, or email. You may disable push notifications and email reminders in the app settings, or reply "TD" in an SMS to unsubscribe from SMS reminders.

  3. 14.2 System Permissions Invoked by viviTalk

    1. Microphone
      1. Scenario/Purpose: Features that require it, such as answering speaking question types.
      2. Personal information collected: Audio.
      3. Consequence of refusal: Unable to answer speaking question types.
    2. Read/Add Photo Album Content
      1. Scenario/Purpose: Provide learning reports and read/store them as images.
      2. Personal information collected: Photo album content.
      3. Consequence of refusal: Unable to read or store photo album content.
    3. Read/Add File Content
      1. Scenario/Purpose: Provide learning reports and read/store them as files.
      2. Personal information collected: File content.
      3. Consequence of refusal: Unable to read or store file content.

  4. 14.3 How We Entrust Processing of Your Personal Information

    • Obtain the List of Installed Apps
      1. Scenario/Purpose: Detect whether specific apps are installed.
      2. Personal information collected: Installed app list.
      3. Consequence of refusal: Unable to read or obtain the installed app list.

  5. 14.4 How We Entrust Processing of Your Personal Information

    1. 1. We share personal information with affiliated and unaffiliated service providers to help us conduct business, such as integrating with our services through application programming interfaces (APIs) to provide or support certain viviTalk services. These providers need access to necessary personal information to perform these tasks and must protect your personal information.
    2. 2. Certain components of viviTalk may link to third-party services that we do not own or control, such as third-party software development kits (SDKs) or APIs integrated for specific functions. Some third-party services may require your personal information, such as location or device information, to provide their services. When you use such third-party services, you must comply with their terms of service and privacy policies. We strongly recommend that you read their privacy policies just as you read ours. We are not responsible for how third parties use the personal information they collect from you, and we cannot control their use. Our Privacy Policy does not apply to other websites linked through our services.
    3. 3. We may conduct technical testing and behavioral audits of SDKs or APIs provided by such partners or service providers and require them to comply with applicable laws, regulations, and agreements to ensure lawful and compliant data collection and use.
    4. 4. The specific third-party SDK/API integrations used by our services are as follows. Please note that third-party SDKs/APIs may change the types of data processed due to version upgrades or policy adjustments; consult their official websites for details:
    SDK Name Developer Information Collected Purpose SDK Privacy Policy Link
    Crash SDK Guangzhou Dongjing Computer Technology Co., Ltd. Crash logs and device information (model, OS version, device status, etc.) App stability analysis and crash monitoring https://yueying-docs.effirst.com/privacy.html
    Umeng+ App Performance Monitoring SDK Umeng Tongxin (Beijing) Technology Co., Ltd. App performance data (launch speed, stutter, anomalies, etc.) and device information (model, OS version, hardware information, etc.) App performance monitoring and optimization https://www.umeng.com/page/policy
    Umeng+ Mobile Statistics SDK Umeng Tongxin (Beijing) Technology Co., Ltd. Device identifiers, usage behavior, Android ID, network information, app installation information, etc. User behavior statistics and analysis to optimize the product experience https://www.umeng.com/page/policy
    Number Authentication - Android Alibaba Cloud Computing (Beijing) Co., Ltd. Phone number, SIM card information, device identifiers (IMEI, IMSI, Android ID, MAC address) One-click login and number authentication services https://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud202112211045_86198.html?spm=a2c4g.11186623.0.0.727039eb0HflH4
    WeChat OpenSDK Android Shenzhen Tencent Computer System Co., Ltd. WeChat login authorization information and sharing-related data (such as shared content and results) Provide WeChat login and sharing capabilities https://support.weixin.qq.com/cgi-bin/mmsupportacctnodeweb-bin/pages/RYiYJkLOrQwu0nb8
    China Unicom Authentication SDK China Unicom Online Information Technology Co., Ltd. Unicom account information and phone number verification data User Unicom account authentication and login https://msv6.wosms.cn/html/oauth/protocol2.html
    Beacon SDK Android Shenzhen Tencent Computer System Co., Ltd. Device identifiers, network information, app runtime information, and app event reporting Analytics and product optimization; app stability assurance https://privacy.qq.com/document/preview/a19a8cf4f2354306b137a7db39d32024
    Umeng Componentized Base Library SDK Umeng Tongxin (Beijing) Technology Co., Ltd. Device information (Android ID, model, OS version), app information (version, runtime status), and network information App analytics, fault diagnosis, and improved stability and user experience https://www.umeng.com/page/policy

  6. 14.5 How We Share Your Personal Information

    1. 1. We do not share users' personal information with companies, organizations, or individuals other than our service providers, except in the following circumstances:
      • Sharing with your explicit consent: With your consent, we share your personal information with other parties.
      • Sharing under statutory circumstances: We may share your personal information as required by laws and regulations, for litigation or dispute resolution, or in response to lawful requests by administrative or judicial authorities.
      • Sharing based on your proactive choice: When you use our services, we may share necessary transaction-related information in your order with relevant service providers, according to your choice, to fulfill after-sales needs.
      • Sharing among affiliates: To provide services, recommend information you may find interesting, or protect the personal and property safety of us, other users, or the public, your personal information may be shared between us and our affiliates. We share only the necessary personal information. If we share sensitive personal information or important corporate information, or if an affiliate changes the purposes and means of processing, we will obtain your additional authorization and consent.

  7. 14.6 How We Transfer Your Personal Information Across Borders

    1. 1. Our headquarters are in Beijing, China, and we deploy servers in Singapore to process data. For unified global management and service provision, we transfer all personal information collected from you to servers in Singapore. You may contact contact@vivitalk.net to exercise your data subject rights. Your personal information may also be transferred, per our instructions, to other countries where processors that provide services to us are located. When transferring your personal information, we comply with Singapore's relevant privacy frameworks and applicable PRC laws and regulations to ensure security.
    2. 2. Regardless of where your personal information is transferred, we will obtain your separate consent and inform you of relevant processing details (see the Cross-Border Data Transfer Statement). We also comply with other applicable PRC requirements, including conducting a personal information protection impact assessment in advance, passing any required security assessments, signing data transfer agreements with overseas recipients, and taking necessary measures to ensure the overseas recipient's processing activities meet PRC standards.

  8. 14.7 How We Transfer Your Personal Information

    1. 1. We do not transfer your personal information to any company, organization, or individual except in the following circumstances:
      • When you agree to this Privacy Policy and use our services through your account, you consent to our transferring your personal information to our affiliates so we can centrally manage your account and other information, enhance security, and provide better, more efficient, and comprehensive products and services.
      • Transfer with your explicit consent: With your consent, we transfer your personal information to other parties.
      • If our service providers undergo a merger, acquisition, or bankruptcy liquidation (or similar circumstances) and your personal information is involved, we require the new company, organization, or individual holding your personal information to continue to be bound by this Privacy Policy; otherwise, we will require them to obtain your authorization and consent again.

  9. 14.8 How We Publicly Disclose Your Personal Information

    1. 1. We disclose your personal information publicly only in the following situations:
      • With your explicit consent or based on your proactive choice.
      • If we determine that you have violated laws or regulations or seriously breached this Privacy Policy, or to protect the personal and property safety of us, other users, or the public, we may publicly disclose your personal information when required by law, legal process, litigation, or mandatory requests from competent government authorities.

  10. 14.9 Exceptions to Prior Consent for Entrusted Processing, Sharing, Transfer, or Public Disclosure

    1. 1. In the following circumstances, entrusted processing, sharing, transfer, or public disclosure of users' personal information does not require prior authorization and consent:
      • Related to national security or national defense security;
      • Related to public safety, public health, or significant public interests;
      • Related to criminal investigation, prosecution, trial, and enforcement of judgments;
      • For safeguarding significant lawful rights and interests of the user or other individuals (including life and property) where it is difficult to obtain consent in time;
      • Information disclosed to the public by the user;
      • Personal information collected from legally disclosed information, such as lawful news reports or government information disclosure channels.
    2. 2. As permitted by law, sharing or transferring de-identified personal information that cannot be restored to identify the user does not constitute entrusted processing, sharing, transfer, or public disclosure of personal information. The retention and processing of such data do not require separate notice or consent.

  11. 14.10 Your Rights

    • Access and Copy Personal Information
      1. You may log in to your viviTalk account at any time and view or copy relevant information from the account main page.
    • Correct and Supplement Personal Information
      1. You may update your nickname and email directly in Settings on the account main page, or email contact@vivitalk.net.
    • Account Cancellation
      1. You may cancel your viviTalk account directly from our mobile app.
    • Delete Personal Information
      1. You may request deletion of your profile information by emailing contact@vivitalk.net. You may also request deletion through the complaint and contact channels provided in this Supplemental Privacy Policy if:
        • Your personal information was collected without your consent;
        • Processing violates applicable laws, regulations, or agreements;
        • We cease viviTalk operations (in which case we will notify you as soon as reasonably practicable);
        • Upon receiving your request, unless retention is required by law, we will delete the relevant personal information promptly.
    • Security Measures
      1. 1. Without affecting the general applicability of this Privacy Policy, we use firewalls, encryption, access controls, and other security technologies and processes to prevent loss, misuse, unauthorized access to, or disclosure of your personal information. We also take organizational and administrative measures such as assigning dedicated departments or personnel, conducting internal security assessments, and organizing training.
      2. 2. If a security incident occurs, we will fulfill notification obligations under applicable law and, as required by Mainland China law, inform you of the basic information about the incident and its potential impact, the remedial measures we have taken, and recommendations for self-protection and risk reduction. We will endeavor to notify you promptly via email, push notifications, SMS, or other means, and may issue a statement on the viviTalk platform.
    • Complaints and Contact Information
      1. 1. If you have questions, comments, or suggestions regarding this Privacy Policy, contact us at:
        contact@vivitalk.net
      2. 2. We will make our best efforts to handle your request as soon as possible, generally no later than fifteen (15) business days.