Last Updated: September 20, 2024
Effective Date: September 20, 2023
Special Notice: This Privacy Policy (hereinafter referred to as "this Policy") applies solely to the products and/or services provided to you by BRAKE MASTERS (hereinafter referred to as "Pingora" or "we"). Before using this application, please read this Policy carefully and ensure that you fully understand all relevant terms; otherwise, do not register, log in, or use the application. Your agreement to this Privacy Policy means only that you understand the features provided by this application and the personal information necessary for those features to function — it does not mean you have agreed to allow us to collect non-essential personal information. The collection of non-essential personal information will be sought with your separate consent during your use of the service. Relevant device permissions will not be enabled by default; when important or sensitive device permissions are involved, we will display a separate pop-up to obtain your consent when you access the corresponding feature. After a permission is enabled, you can close it at any time through the system permission settings. Declining to enable a permission for a given feature will not affect your normal use of other unrelated features. Important content relating to sensitive personal information and your personal information rights has been highlighted in bold — please pay special attention. If you are a minor under 18 years of age, please read this Policy carefully with your parent or legal guardian and obtain their consent before using Pingora's products and/or services.
Summary
We deeply understand the importance of personal information to you and appreciate your trust in us. Through this Policy, we will explain how Pingora collects, stores, protects, uses, and shares your information, and describe the rights you enjoy. Key points are as follows:
1. To help you understand what types of information we need to collect when you use our services and why, we will explain this in connection with each specific service.
2. To provide you with our services, we will collect your information in accordance with the principles of lawfulness, legitimacy, and necessity.
3. If sharing your information with third parties is necessary to provide you with services, we will assess the legality, legitimacy, and necessity of that third party's collection of your information. We will require third parties to take protective measures for your information and to strictly comply with relevant laws, regulations, and regulatory requirements. Additionally, we will obtain your consent or confirm that the third party has obtained your consent in the forms required by applicable law, including agreements, in-context confirmations, and pop-up prompts.
4. If obtaining your information from third parties is necessary to provide you with services, we will require those third parties to explain the source of the information and ensure its legality. If our business activities require processing your personal information beyond the scope of the authorization you originally granted to the third party, we will obtain your explicit consent.
5. You may access and manage your information, set privacy features, cancel your Pingora account, or submit complaints through the methods described in this Policy.
You may read the corresponding sections according to the index below to learn more about the specific provisions of this Policy:
This Policy will help you understand the following:
I. Definitions and Interpretations
II. How We Collect and Use Your Personal Information
III. How We Use Cookies and Similar Technologies
IV. How We Share Your Personal Information Externally
V. How We Protect Your Personal Information
VI. How We Store Your Personal Information
VII. How You Can Exercise Your Rights Over Your Personal Information
VIII. How We Protect the Personal Information of Minors
IX. How We Update This Policy
X. How to Contact Us
XI. Other
I. Definitions and Interpretations
1. Pingora Products and/or Services: includes the products and/or services provided by Pingora (hereinafter referred to as "this Application").
2. Pingora Services: refers to the Pingora products and/or services provided to users by BRAKE MASTERS, hereinafter referred to as "this Service," including the software and related services for adding friends, creating group chats, and voice/video calls.
3. BRAKE MASTERS: the operator of Pingora, professionally engaged in intelligent voice and language technology research, software and chip product development, voice information services, and information communication security technology. Registered address/main business address: 6179 E Broadway Blvd, Tucson, Arizona 85711-4028, United States; contact number: +1 (409) 751-5143. For more detailed information about our company and platform, you may contact us through the contact information provided in Chapter X of this Policy.
4. User: refers to individuals who register, log in, and use this Application and access, browse, or upload data to Pingora's services, referred to herein more often as "you."
5. Affiliated Company: refers to any entity that directly or indirectly controls BRAKE MASTERS, is controlled by BRAKE MASTERS, or is under common control with BRAKE MASTERS. "Control" and "controlled by" refer to the right to direct the management policies of a party through voting rights, contracts, or other means.
6. Account: refers to the user account you hold after completing registration with real information; you are responsible for safeguarding your account. You shall bear legal responsibility for all actions taken under your account.
7. Personal Information: personal information refers to various types of information recorded electronically or otherwise that relates to identified or identifiable natural persons, excluding anonymized information. For the avoidance of doubt, personal information includes but is not limited to sensitive personal information.
8. Sensitive Personal Information: sensitive personal information refers to personal information that, if leaked or illegally used, could easily lead to infringement of the personal dignity of natural persons or harm to their personal or property safety, including biometric identification, religious beliefs, specific identities, medical and health information, financial accounts, location tracking data, and personal information of minors under the age of 14.
9. Processing of Personal Information: the processing of personal information includes the collection, storage, use, processing, transmission, provision, disclosure, and deletion of personal information.
10. Personal Information Processor: a personal information processor refers to an organization or individual that independently determines the purpose and method of processing personal information in personal information processing activities.
11. Personal Information Subject: the personal information subject refers to the natural person identified or associated with the personal information.
12. Automated Decision-Making: automated decision-making refers to activities that automatically analyze and evaluate individuals' behavioral habits, interests and preferences, or economic, health, or credit status through computer programs, and make decisions accordingly.
13. De-identification: de-identification refers to the process by which personal information is processed so that it cannot identify a specific natural person without the use of additional information.
14. Anonymization: anonymization refers to the process by which personal information is processed so that a specific natural person cannot be identified and the information cannot be restored.
15. Device: a device refers to any equipment that can be used to access Pingora's services, such as desktop computers, laptops, tablets, or smartphones.
16. Unique Device Identifier: a unique device identifier (proprietary ID or UUID) refers to a string of characters programmed into a device by its manufacturer that can be used to uniquely identify the corresponding device (e.g., the IMEI number of a mobile device). Unique device identifiers have multiple uses, including providing advertising when cookies are unavailable.
17. IP Address: every device connected to the internet is assigned a number called an Internet Protocol (IP) address. These numbers are usually assigned by geographic region. An IP address can generally be used to identify the location where a device connects to the internet.
18. SSL: SSL (Secure Socket Layer) is a security protocol implemented over the transport communication protocol (TCP/IP). SSL supports various types of networks and provides three basic security services, all achieved through the use of public key and symmetric key technology to ensure information confidentiality.
19. Information Collection Technologies:
(1) Cookie: A cookie is a small text file placed by the website server in the client (your computer, mobile phone, or other smart terminal) when you browse a webpage, and can be used to improve your user experience.
(2) Log Files: Log files store automatically collected data, including Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamps, and clickstream data.
(3) ET Tag (Entity Tag): An ET Tag is an HTTP protocol header transmitted silently between an internet browser and an internet server. It can be used as an alternative to cookies to track individual users, allowing us to better understand and improve our services.
(4) JavaScript: JavaScript is a programming language used to create more interactive and dynamic web pages. JavaScript can set, read, and delete cookies.
II. How We Collect and Use Your Personal Information
BRAKE MASTERS, as the personal information processor, will follow the principles of lawfulness, legitimacy, necessity, and good faith, and collect and use your personal information for the purposes described below.
1. Personal Information You Actively Provide During Our Provision of Products and/or Services
1.1 According to applicable regulations on the scope of necessary personal information for mobile internet applications, Pingora falls under the "chat and communication" category of apps, and the necessary personal information is: the registered user's mobile phone number. To implement our basic business functions, you only need to provide us with the basic necessary personal information corresponding to that function, except as otherwise required by applicable laws, regulations, and normative documents. If you refuse to provide this information, we will be unable to provide you with the corresponding service. Please note: if the personal information you provide belongs to someone else, please ensure you have obtained that person's consent.
(1) When registering and logging into your Pingora account, you must log in to your Pingora account to enjoy Pingora's products and/or services. When you first log in via a third-party account (iOS additionally offers phone number registration), we will automatically create a Pingora account for you. Your account and password will be encrypted and stored on our servers, accessible only by you; we recommend keeping your password confidential to prevent unauthorized access.
(2) To provide you with BRAKE MASTERS Pingora device binding services, after you consent and enable camera/camcorder permissions, we will activate your camera/camcorder permissions and collect scanned image information to facilitate adding friends, video communication, and related operations.
1.2 To provide you with higher-quality Pingora products and/or services, we may need to collect the following information. Refusing to provide the information below will not affect your normal use of the basic business functions described in Section 1.1, but you may be unable to access the enhanced user experience offered by these extended functions. These extended business functions include:
(1) To provide you with services for sending pictures and videos to chat contacts and sending files to chat contacts, after you consent and enable the permission to read device storage content/access photos and media on your device, we will collect image/video information uploaded from your gallery (photo library/video library). Please note: even if you have consented to enable the permission to access photos and media on your device, we will only access photos through that permission when you actively initiate the image upload function in the client.
(2) To provide you with voice call services, after you consent and enable microphone permissions, we will collect your voice information. Please note: even if you have consented to enable microphone permissions, we will only collect voice information through the microphone permission when you actively activate the in-client microphone or audio/video recording function.
(3) To provide you with message notification services, after you consent and enable the permission to read call status and mobile network information, we will collect your device ID for push notifications. Please note: even if you have consented to enable notification permissions, we will only send you relevant notification information. To disable notifications, you can turn them off in your phone's "Settings - Notifications - Pingora." The exact path may vary slightly depending on your phone brand.
You understand and agree that the above services may require you to enable access permissions on your device for your camera, photo album (photo library), and microphone (voice) to enable the collection and use of information related to those permissions. You can view the status of these permissions in your device settings or our client, and may choose to enable or disable these permissions at any time. Specifically, you may refer to the procedures described in Chapter VII of this Policy under "Changing the Scope of Your Authorized Consent or Withdrawing Authorization."
Please note: enabling any permission means you authorize us to collect and use the relevant personal information to provide you with the corresponding service; closing any permission means you have withdrawn that authorization, and we will no longer collect and use the relevant personal information based on that permission, nor will we be able to provide the service corresponding to that permission. However, your decision to close a permission will not affect information collection and use that took place before the permission was closed.
2. Personal Information We Proactively Collect During Our Provision of Products and/or Services
Under applicable laws and regulations, to protect your account security and provide you with better quality services, we will collect and use the following information generated during your use of Pingora's products and/or services:
(1) Device Information
When you use Pingora's products and/or services, we may receive and record relevant device information based on specific permissions granted during software installation and use, to ensure the security of your account and usage, including device name, device model, operating system version, screen information, operating system information, device hardware model, device binding time, number of bound devices, and the Pingora application installation list.
(2) Log Information
When you use Pingora's products and/or services, we will automatically collect detailed information about your use and save it as network logs, including Pingora launch/exit records, login records, logout records, account cancellation records, guardian status, guardian records, operating system information, login IP information, time and duration of use, and software event information (such as restarts, upgrades, errors, crashes, etc.) to help us analyze usage patterns, optimize Pingora products and/or services, and provide you with a better service experience.
(3) Text Information
When you use clipboard paste-to-screen services, you will need to provide us with your clipboard content so that we can provide you with more convenient text pasting and selection services. Clipboard content will not be uploaded to the cloud when you use the clipboard paste-to-screen function.
3. Personal Information Processing Notes
(1) In accordance with applicable laws and regulations, we may technically process your personal information so that individual users cannot be precisely identified from that information, and conduct anonymized or de-identified academic research or statistical analysis on the processed information (including using anonymized or de-identified voice information for model algorithm training), to better improve product functions and service capabilities.
(2) Under applicable laws and regulations, processing your personal information in the following circumstances does not require your consent:
• Necessary for the conclusion or performance of a contract to which the individual is a party, or necessary for human resources management in accordance with lawfully established labor rules and collective contracts;
• Necessary for the performance of statutory duties or statutory obligations;
• Necessary in response to public health emergencies, or in urgent circumstances to protect the life, health, and property safety of natural persons;
• Processing personal information within a reasonable scope for news reporting, public opinion supervision, and other activities in the public interest;
• Processing within a reasonable scope personal information that has been lawfully disclosed to the public;
• Other circumstances as provided by laws and administrative regulations.
III. How We Use Cookies and Similar Technologies
We may collect and use your information through cookies or similar technologies, store such information as log data, and use it for the following purposes:
(1) To remember your identity. For example, cookies help us recognize you as our registered user, or save information about your preferences or other details you have provided to us;
(2) To analyze your use of our services. For example, we may use cookies to understand what activities you perform using our services, or which pages or services are most popular with you.
Please be aware that advertisers or other third-party service providers may place cookies and similar technologies on our products and services. These cookies and similar technologies may collect non-personally identifiable information about you for de-identified research and analysis, to improve our content and layout, and to improve our products and services. The collection and use of such information by these third-party cookies and similar technologies is governed by the relevant users' own privacy policies, and we are not responsible for third-party cookies and similar technologies. You may refuse or manage cookies and similar technologies through your browser settings. However, please note that if cookies or similar technologies are disabled, you may not be able to enjoy the best service experience, and some services may not function properly.
IV. How We Share Your Personal Information Externally
1. Entrusted Processing
To provide you with more complete and higher-quality products and services, we may entrust third parties (including companies, organizations, and individuals) to process certain of your personal information. For third parties to whom we entrust the processing of your personal information, we will sign strict data processing agreements with them, clearly specifying the purpose, duration, processing method, type of personal information, protective measures, and the rights and obligations of both parties, and will supervise the third party's personal information processing activities. We require third parties to process your personal information only in accordance with our requirements, the provisions of this Policy, and any other relevant confidentiality and security measures. If you refuse to allow third parties to collect personal information necessary for them to provide services, you may be unable to enjoy the services provided by those third parties when using Pingora products and/or services.
2. Sharing
We will not share your personal information with third parties (including companies, organizations, and individuals), except in the following circumstances:
(1) Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with third parties.
(2) Sharing under legal circumstances: We may share your personal information with third parties in accordance with laws and regulations, for dispute resolution needs, or as required by administrative or judicial authorities in accordance with law.
(3) Sharing with affiliated companies: To connect with our other products or services and provide you with better services, or to protect the personal and property safety of BRAKE MASTERS's affiliated companies, other users, or the public, your information may be shared among BRAKE MASTERS's affiliated companies. We will only share your personal information among BRAKE MASTERS's affiliated companies for specific, explicit, and lawful purposes within the scope declared in this Policy, and will only share information necessary for providing services. For information shared with affiliated companies, we will require them to adopt protective measures no less stringent than those stated in this Policy and to strictly comply with applicable laws and regulations. Affiliated companies will need to obtain your authorization again if they wish to change the purpose of processing your personal information.
(4) Sharing with authorized partners: To achieve the purposes stated in this Policy, some of our services will be jointly provided by us and authorized partners. We may share certain personal information with partners to provide better customer service and user experience. We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and will only share the personal information necessary for providing services. Our partners have no right to use the shared personal information for any other purpose. Currently, our authorized partners include the following types:
a. Advertising and analytics service partners. Unless permitted by you, we will not share your personally identifiable information with partners who provide advertising and analytics services. We will provide these partners with information about the reach and effectiveness of their advertising without providing your personally identifiable information, or we will aggregate this information so that it does not identify you personally.
b. Vendors, service providers, and other partners. We send information to vendors, service providers, and other partners who support our business, including those who provide technical infrastructure services, analyze how our services are used, measure the effectiveness of advertising and services, provide customer service, or conduct academic research and surveys. For companies, organizations, and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to process personal information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures, and not to exceed the agreed processing purposes or methods.
(5) Third-party SDKs
Some functions in Pingora are provided by third-party institutions we partner with (hereinafter referred to as "SDK Technology Service Providers") in the form of SDK plugins. SDK Technology Service Providers will obtain corresponding permissions and information as necessary to provide you with functions or services. We conduct security monitoring of all SDKs integrated into this Application to ensure that these SDKs use only the basic permissions necessary for their functions or services.
3. Transfer
We will not transfer your personal information to any third party (including companies, organizations, and individuals), except in the following circumstances:
(1) Transfer with your explicit consent;
(2) Transfer required by applicable laws and regulations, legal proceedings, or mandatory administrative or judicial requirements;
(3) In the event of a merger, acquisition, or bankruptcy liquidation involving the product service provider where personal information transfer is involved, we will notify you of the name and contact information of the recipient, and require the new holder of your personal information to remain bound by this Policy. Where the recipient changes the original processing purpose or method, we will require them to obtain your authorization and consent again.
4. Public Disclosure
We will only publicly disclose your personal information in the following circumstances:
(1) With your separate consent or based on your active choice, we may publicly disclose your personal information;
(2) Under legal requirements, legal proceedings, litigation, or mandatory requirements from government authorities, we may publicly disclose your personal information.
(3) If we determine that you have violated laws and regulations or seriously violated the relevant agreement rules of this product, or to protect the personal and property safety of users or the public, we may disclose information about you in accordance with applicable laws and regulations or the relevant agreement rules of this product.
5. Exceptions to Prior Authorization for Entrusted Processing, Sharing, Transfer, and Public Disclosure
In the following circumstances, entrusted processing, sharing, transfer, and public disclosure of your personal information does not require your prior authorization and consent:
(1) Related to our fulfillment of obligations as required by laws and regulations;
(2) Directly related to national security or national defense security;
(3) Directly related to public safety, public health, or significant public interest;
(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments;
(5) Necessary to protect significant legitimate rights and interests of your life or property, or those of others, when it is difficult to obtain consent from the person;
(6) Personal information that you have disclosed to the public yourself;
(7) Personal information collected from legally disclosed information, such as lawful news reports and government information disclosure channels.
Please note: under applicable laws and regulations, sharing, transferring, and publicly disclosing anonymized personal information, where the data recipient cannot restore or re-identify the personal information subject, is not considered external sharing, transfer, or public disclosure of personal information; the storage and processing of such data does not require additional notification to or consent from you.
V. How We Protect Your Personal Information
1. We attach great importance to the privacy and protection of users' personal information, and will take reasonable measures to protect users' personal information. Except as provided by laws and regulations or otherwise stipulated in this Policy, BRAKE MASTERS will use various security technologies and procedures to establish a comprehensive management system to protect your personal information from unauthorized access, use, or disclosure. We will not publicly disclose or share users' personal information with third parties without users' permission, and will employ professional encrypted storage and transmission methods for relevant information to ensure the security of users' personal information.
2. We will work with reputable suppliers and security partners, actively conduct risk impact assessments, and regularly hold training, testing, and promotional activities to implement data security and personal information protection work comprehensively.
3. Data Security Measures
(1) BRAKE MASTERS will adopt industry-standard security protection measures, including establishing reasonable institutional regulations and security technologies to prevent your personal information from being accessed, used, or modified without authorization, and to avoid data damage or loss. For example, our network services use encryption technologies such as Transport Layer Security (TLS) protocols, providing browsing services through HTTPS to ensure the security of user data during transmission; we use encryption technologies (TLS, SSL), anonymization or de-identification processing, and protection mechanisms to encrypt and store user personal information; we establish data classification and grading systems, data security management standards, and data security development standards; we allow only employees, affiliates, and partners who need to know this information to access personal information through confidentiality agreements, and have established strict access permission controls and monitoring mechanisms, while requiring all persons who access your personal information to fulfill corresponding confidentiality obligations. Failure to fulfill these obligations may result in legal liability or termination of cooperation with BRAKE MASTERS. We also hold security and privacy protection training courses, and develop and implement emergency response plans for personal information security incidents.
(2) We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. We will only retain your personal information for the period necessary to achieve the purposes described in this Policy, unless an extended retention period is required or permitted by law.
(3) The internet is not an absolutely secure environment, and email, instant messaging, and communications with other users are not encrypted. We strongly recommend that you do not send personal information via such methods. Please use complex passwords to help us keep your account secure.
(4) The internet environment is not 100% secure. BRAKE MASTERS will make every effort to ensure the security of any information you send to us. If BRAKE MASTERS's physical, technical, or administrative safeguards are compromised, resulting in unauthorized access, public disclosure, alteration, or destruction of information that causes harm to your legitimate rights and interests, we will bear corresponding legal responsibility.
(5) In the unfortunate event of a personal information security incident, BRAKE MASTERS will promptly notify you in accordance with legal requirements about: the cause of the security incident, possible harm, types of personal information involved, measures we have taken or will take, and recommendations for how you can reduce risk. We will notify you promptly by email, text message, phone call, or push notification; when it is difficult to notify each individual personally, we will adopt reasonable and effective methods to issue public notices. BRAKE MASTERS will also proactively report on the handling of personal information security incidents as required by regulatory authorities.
VI. How We Store Your Personal Information
This product and/or service is provided to users in the applicable jurisdiction. In principle, personal information collected within our operating territory is stored within our servers located in our primary operating region and will not be transferred cross-border unless permitted by law.
1. Storage Location
BRAKE MASTERS complies with applicable laws and regulations; information and data collected about you will be stored on our servers. The following cases are exceptions:
• As expressly required by laws and regulations;
• With your explicit authorization;
• Personal initiatives by you such as cross-border transactions via the internet.
2. Storage Period
In general, we will retain your personal information for the minimum period necessary to achieve the processing purposes described in this Policy during your use of Pingora products and/or services, unless otherwise required by applicable laws, regulations, or normative documents. After the above period expires, or after you request deletion of your personal information or cancellation of your account, we will delete your personal information as soon as practicable in accordance with applicable laws and regulations. However, in the following circumstances, BRAKE MASTERS must change the storage duration to comply with legal requirements:
• To comply with applicable laws, regulations, and related provisions;
• To comply with court judgments, rulings, or other legal procedures;
• To comply with requirements of relevant government agencies or legally authorized organizations;
• For purposes reasonably necessary to enforce related service agreements or this Policy, maintain social public interests, or protect the personal and property safety or other legitimate rights and interests of BRAKE MASTERS's customers, BRAKE MASTERS itself, other users, or employees.
After you cease using Pingora, BRAKE MASTERS will cease collecting and using your information, except as required by applicable laws, regulations, or regulatory authorities.
When the relevant services of Pingora cease operations, we will notify you via notifications and public announcements, and will delete your personal information stored on servers within the period required by applicable laws and regulations.
VII. How You Can Exercise Your Rights Over Your Personal Information
1. In accordance with applicable laws, regulations, and standards, you enjoy certain rights in personal information processing activities, specifically including:
• You have the right to know and to make decisions regarding personal information processing, and the right to restrict or refuse others from processing your personal information, except as otherwise provided by laws and administrative regulations;
• You have the right to access and copy your personal information from the personal information processor, except as otherwise provided by law;
• You have the right to request transfer of your personal information to a personal information processor you designate;
• If you find that your personal information is inaccurate or incomplete, you have the right to request the personal information processor to correct or supplement it;
• You have the right to request deletion of your personal information;
• You have the right to require the personal information processor to explain and clarify its personal information processing rules.
2. We guarantee your exercise of the aforementioned rights over your personal information, and provide you with relevant operation paths. Specifically, you may refer to the following steps for related operations:
(1) Obtaining a Copy of Your Personal Information
You have the right to obtain a copy of your personal information. You may contact our customer service through the methods described in Chapter X of this Policy, and we will process your request within 15 business days.
(2) Transferring Your Personal Information
You have the right to request transfer of your personal information to a personal information processor you designate. Where applicable conditions are met, we will provide you with a transfer pathway. You may contact our customer service through the methods described in Chapter X of this Policy, and we will process your request within 15 business days.
(3) Changing the Scope of Your Authorized Consent or Withdrawing Authorization
You can withdraw your authorization through your device's Settings - Applications - Permission Settings. You may also withdraw all authorization for our continued collection of your personal information by canceling your account. If you encounter operational issues during this process, you may contact us through the methods provided at the end of this Privacy Policy. Please understand that after you perform the above operations, we will be unable to continue providing you with the services corresponding to the withdrawn consent or authorization, but this will not affect personal information processing that occurred before you withdrew your consent or authorization.
(4) Canceling Your Account
You have the right to cancel your Pingora account. You may contact our customer service through the methods described in Chapter X of this Policy to assist with account cancellation. After receiving your request, we will require you to provide your account (phone number) and an SMS verification code to verify your identity; upon successful verification, we will complete the cancellation within 15 business days. After successful cancellation, we will promptly delete your personal information or anonymize it as required by laws and regulations.
(5) Responding to Your Requests
BRAKE MASTERS will take appropriate technical measures to ensure that you can access, supplement, correct, or delete your personal data, or request BRAKE MASTERS to supplement, correct, delete, copy, or transfer relevant information through feedback or complaint channels published via Pingora's products and/or services. After receiving your application, BRAKE MASTERS will process it according to procedures. For security, BRAKE MASTERS may first require you to verify your identity before processing your request. We will reply within 15 business days. For reasonable requests, BRAKE MASTERS will in principle not charge fees; however, for requests that are repetitive or exceed reasonable limits, we may charge a reasonable cost fee. BRAKE MASTERS may refuse requests that are frivolous and repetitive, require excessive technical means, pose risks to the legitimate rights and interests of others, or are highly impractical. If you are unable to access, supplement, correct, delete, copy, or transfer your personal information, or if you believe BRAKE MASTERS has violated any laws or regulations or your agreements regarding the collection or use of your personal information, you may contact us through our official feedback channels for the relevant products or services.
Please note: in the following circumstances, we will be unable to respond to your request:
(1) Related to our fulfillment of obligations as required by laws and regulations;
(2) Directly related to national security or national defense security;
(3) Directly related to public safety, public health, or significant public interest;
(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments;
(5) We have sufficient evidence that you have subjective malicious intent or are abusing your rights;
(6) Necessary to protect significant legitimate rights and interests of your life or property, or those of others, when it is difficult to obtain consent from the person;
(7) Responding to your request would cause serious harm to the legitimate rights and interests of you, other individuals, or organizations;
(8) Involving trade secrets.
VIII. How We Protect the Personal Information of Minors
1. BRAKE MASTERS attaches great importance to the protection of minors' personal information, and will protect minors' personal information in accordance with the provisions of applicable national laws and regulations.
2. We treat anyone under the age of 18 as a minor. In accordance with applicable laws and regulations, if you are a minor who has reached the age of 14, we will obtain your or your guardian's consent before collecting your personal information, and if you, your parents, or other guardians request us to correct or delete minors' personal information, we will promptly take measures to do so, except as otherwise provided by laws and administrative regulations.
3. If you are a minor under the age of 14 (hereinafter referred to as a child), we will obtain the consent of your parents or other guardians before collecting your personal information.
4. When processing children's personal information, we will take the following measures to ensure protection: for children's personal information we collect, in addition to following this Policy's provisions on user personal information, we will adhere to the principles of legitimacy and necessity, informed consent, clear purpose, security, and lawful use, strictly comply with applicable laws and regulations for storage, use, and disclosure, and will not exceed the period necessary to achieve the purpose of collection and use; upon expiry, we will delete children's personal information.
IX. How We Update This Policy
1. To provide you with better services, Pingora's products and/or services will be updated and changed from time to time, and we will revise this Policy accordingly; such revisions constitute part of this Policy. However, we will not reduce your rights under this Policy without your explicit consent.
2. After this Policy is updated, we will release an updated version on Pingora, and will remind you to read the updated Privacy Policy again through app store new version announcements or pop-ups. If you disagree with this Policy or have objections to changes or updates, you may choose to stop using Pingora's products and/or services or cancel your Pingora account. Please note, however, that your actions and activities before account cancellation or before you stop using this service will remain subject to this Policy.
3. For significant changes, we will provide more prominent notices (including but not limited to email, SMS, or special prompts on browsing pages, explaining the specific changes to this Policy).
Significant changes referred to in this Policy include but are not limited to:
(1) Significant changes to our service model, such as the purposes for processing personal information, the types of personal information processed, or the way personal information is used;
(2) Significant changes in our ownership structure or organizational structure, such as changes caused by business adjustments, bankruptcy, mergers and acquisitions, etc.;
(3) Changes to the main parties with whom personal information is shared, transferred, or publicly disclosed;
(4) Significant changes in your rights regarding personal information processing and how you exercise them;
(5) Changes to the department responsible for handling personal information security, contact information, or complaint channels;
(6) When a personal information security impact assessment report indicates high risk;
(7) Changes made in response to national policies or laws and regulations as they are promulgated and implemented.
X. How to Contact Us
To better protect your personal information, we have established a dedicated network security and personal information protection department. If you have any questions or suggestions about this Policy or your personal information during your use of Pingora, please contact us through the following contact methods:
Contact Phone: +1 (409) 751-5143
Contact Email (Personal Information Protection Officer): devanteh@brakemasters.cyou
Contact Address: 6179 E Broadway Blvd, Tucson, Arizona 85711-4028, United States
If you are not satisfied with our response, especially if you believe our personal information processing activities have harmed your legitimate rights and interests, and after providing us with feedback we are unable to provide you with a satisfactory response and refuse to make improvements, you may file a complaint or report with the relevant regulatory authority.
XI. Other
Any disputes related to this Policy shall be resolved through friendly negotiation; if they cannot be resolved through negotiation, you hereby agree to bring legal action before any court with jurisdiction.
If a court with jurisdiction determines or rules that any provision of this Policy is invalid, that provision will be removed from this Policy, but the invalidity of that provision will not affect the validity of the remaining provisions of this Policy. The remaining provisions of this Policy will continue to be in effect.