Lynse

Privacy Policy (App)

Updated: January 7, 2026

Published: January 7, 2026

Effective: January 7, 2026

This Privacy Policy (hereinafter referred to as "this Policy") applies solely to the application products and/or services (hereinafter referred to as "the Products" or "the Services") provided to you by Shanghai Tianqi Lingguang Technology Co., Ltd. (hereinafter referred to as "the Company," "we," "us," or "our"). Before using the Products, please read this Policy carefully to understand how we process your personal information. Provisions concerning sensitive personal information and matters material to your personal information rights are highlighted in bold. Please pay special attention to these sections. We do not provide our Services to minors. Please confirm that you are at least 18 years of age before using the Services. If you are under 18, do not register for or use the Services, and do not provide us with any personal information. If we discover that you are a minor, we will cease providing the Services and delete the relevant information.

Important Notices:

  1. Your agreement to this Policy solely indicates that you understand the functions offered by the Products and the necessary personal information required for their operation. It does not signify your consent for us to collect non-essential personal information. We will seek your separate consent for the collection of non-essential personal information based on your authorization during use.

  2. For sensitive personal information, we will obtain your separate consent through pop-up dialogs or similar means before collection.

  3. Corresponding device permissions are not enabled by default. When important or sensitive device permissions are involved, we will seek your separate consent through pop-up dialogs or similar means at the time you use the relevant business function. After a permission is enabled, you may disable it at any time on the Products' permission settings page or in your device's system permission settings. Refusing to enable a permission for a particular business function will not affect the normal use of other unrelated business functions.

  4. To help you better understand the details of function-related permission requests, you may click to read the App Permissions List:

    The App Permissions List explains the types of each permission, the corresponding business function, when the permission is invoked, and the potential impact of denying the permission.

    Please be aware that enabling any permission constitutes your authorization for us to collect and use the relevant personal information to provide the corresponding service. Once you disable a permission, it is deemed a withdrawal of the corresponding authorization, and we will cease collecting and using your personal information based on that permission and will be unable to continue providing the corresponding service. Your decision to disable a permission does not affect any information processing previously conducted based on your authorization.

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 Commission Processing, Share, Transfer, and Publicly Disclose Your Personal Information

V. How We Protect Your Personal Information

VI. How We Store Your Personal Information

VII. How You Can Manage Your Personal Information Rights

VIII. How We Protect Minors' Personal Information

IX. How Your Personal Information Is Transferred Globally

X. How We Update This Policy

XI. How to Contact Us

XII. Miscellaneous

I. Definitions and Interpretations

  1. lynse Products and/or Services (hereinafter referred to as "the Products" or "the Services") refer to the various products and services provided or operated by the Company, including but not limited to the lynse App, the lynse website, and other related online services.

  2. Shanghai Tianqi Lingguang Technology Co., Ltd. (hereinafter referred to as "the Company," "we," "us," or "our"): the operator of lynse. Registered address/principal office: Room 1901, 19th Floor, Building A, No. 391 Guiping Road, Xuhui District, Shanghai, China 200233. If you wish to learn more about our company and platform, you may contact us using the information provided in Section XI of this Policy.

  3. User: refers to any person who registers, logs in, or uses this software and enables, browses, or uploads data to the lynse Services. In this Policy, Users are more commonly referred to as "you."

  4. Affiliates: means any entity that directly or indirectly controls, is controlled by, or is under common control with the Company. "Control" and "controlled" refer to the power to direct the management policies of an entity through voting rights, contracts, or otherwise.

  5. Account: refers to the user account you obtain after completing registration with authentic information. You are responsible for safeguarding your Account and shall bear legal responsibility for all activities conducted under your Account.

  6. Personal Information: means any information recorded electronically or otherwise that relates to an identified or identifiable natural person, excluding information that has been anonymized. For the avoidance of doubt, Personal Information includes Sensitive Personal Information as defined below.

  7. Sensitive Personal Information: means personal information that, once leaked or unlawfully used, may easily result in harm to a natural person's dignity or endanger their personal or property safety, including biometric data, religious beliefs, specific identity, medical health, financial accounts, whereabouts and trajectory, and the personal information of minors under 14 years of age.

  8. Processing of Personal Information: includes the collection, storage, use, processing, transmission, provision, disclosure, and deletion of personal information.

  9. Controller: means an organization or individual that independently determines the purposes and means of processing personal information.

  10. Data Subject: means the natural person identified or associated with the personal information.

  11. Automated Decision-Making: means the process of automatically analyzing and evaluating an individual's behavioral habits, interests, or economic, health, or credit status through computer programs, and making decisions based thereon.

  12. De-identification: means the process of processing personal information so that, without the use of additional information, a specific natural person cannot be identified.

  13. Anonymization: means the process of processing personal information so that a specific natural person cannot be identified and the process is irreversible.

  14. Device: means any equipment that can be used to access the Products, such as a desktop computer, laptop, tablet, or smartphone.

  15. Unique Device Identifier: means a string of characters programmed into a device by the device manufacturer that can be used to uniquely identify the corresponding device. Unique device identifiers have multiple purposes, including providing advertising when cookies cannot be used.

  16. IP Address: each device connected to the internet is assigned a number called an Internet Protocol (IP) address. These numbers are typically assigned by geographic region. IP addresses can generally be used to identify the location of a device when it is connected to the internet.

  17. SSL: SSL (Secure Socket Layer), also known as the Secure Sockets Layer, is a security protocol implemented on the Transport Communication Protocol (TCP/IP). SSL supports various types of networks and provides three basic security services, all of which achieve information confidentiality through the use of public key and symmetric key technologies.

II. How We Collect and Use Your Personal Information

As a controller of personal information, the Company follows the principles of lawfulness, fairness, necessity, and good faith in collecting and using your personal information for the purposes described below.

Personal Information You Actively Provide

lynse App is classified as a "utility" application. To provide you with account registration and login, adding lynse devices, transcription and summarization, and other functional services, you only need to provide the basic and necessary personal information corresponding to each function, unless otherwise required by applicable laws, regulations, or normative documents. If you refuse to provide such information, we will be unable to provide you with the corresponding functional services.

Please note: If you provide personal information that is not your own, please ensure that you have obtained the consent of the relevant data subject(s).

The complete functions of the lynse App and the personal information processing details are as follows:

1.1 App Runtime

(1) Necessary and Non-Necessary Information Scope

When you use the App, we collect your network type, IP address, operating system type, App process name, operating system version, and device resolution to identify whether you are a real natural person user, comprehensively assess your account risk, perform identity verification, detect and prevent security incidents, and take necessary recording, analysis, and response measures in accordance with applicable law. ** This information is necessary for this function. If you do not agree, you will not be able to use the App normally.**

1.2 Account Registration and Login

(1) Necessary and Non-Necessary Information Scope

To ensure the security of your personal space, you must register and log in to a "lynse account" before you can use other services that require registration and login, including voice-to-text, device connection, and purchasing credits. When registering and logging in, you must provide your mobile phone number and enter an SMS verification code so that we can verify your user identity. ** This information is necessary for this function. If you do not provide it, you will not be able to complete registration/login.**

1.3 Profile Management

(1) Necessary and Non-Necessary Information Scope

While using the Products, you may choose to modify your nickname, take a photo for your avatar, or select an image from your photo library to upload as your avatar. We will collect your nickname and image information. This information is non-necessary. If you do not provide it, it will not affect your registration, login, or other functions of the Products.

(2) Permission Scope

If you choose to take a photo or select an image from your photo library, we need to access your camera permission (read), photo library permission (read), or local file access permission. If you refuse, you will not be able to insert photos, but it will not affect your use of transcription and summarization, or the viewing, editing, and sharing of transcription results.

1.4 Adding Devices

(1) Necessary and Non-Necessary Information

To provide the device-adding function, we collect the device's serial number (SN), MAC address, Wi-Fi SSID, and specific sensor list (Bluetooth) to pair and connect the Product with the device. ** This information is necessary for the device-adding function.** After pairing and connection are complete, we will only transmit data via Bluetooth when you actively enable recording and file transfer. ** This Bluetooth data transmission is non-necessary for the device-adding function.**

(2) Permission Scope

When adding a device, we need to access your Bluetooth permission and location access permission (only for Android systems below version 13). If you refuse to enable these permissions, you will not be able to add a device.

1.5 Subscription Service Management and Payment

When you choose to purchase subscription services or transcription duration in the Products, we collect your order information (including subscription/order type, order number, order source, user ID, order price, actual payment price, payment channel, payment method, order creation time, and order payment time). This information is necessary for us to confirm your transaction, activate the corresponding credits for you, and handle possible refunds or after-sales issues. ** If you do not agree, you will not be able to subscribe and pay normally.**

1.6 Transcription and Summarization

(1) Necessary and Non-Necessary Information Scope

When you use the transcription and summarization function, we collect audio and video files that you actively select and upload from your device, or ** voice/audio files** recorded by your lynse device and synced to the Products. We also collect the ** text information** generated after transcription and analysis to assess your needs and provide real-time processing feedback so that we can provide you with a record-viewing service. ** This information is necessary for the transcription and summarization function. If you cannot provide it, you will not be able to use the transcription and summarization function.**

During the transcription and summarization process, you may choose to insert photos by taking a picture or selecting an image from your photo library. We will collect your image information. This information is non-necessary. If you do not provide it, it will not affect your use of transcription and summarization or other functions of the Products.

When using the transcription and summarization function, you may choose to import audio files or export audio, transcription results, and summary content. To enable these file import and export operations, we collect your device's SD card directory information. This information is necessary for file transfer. If you refuse to provide it, file import and export operations within the transcription and summarization function may be affected.

You must not use technologies such as deep learning, virtual reality, or generative artificial intelligence to create, upload, copy, transmit, or distribute false news or other information prohibited by law, or misrepresent synthetic content as natural content. When you publish or distribute non-authentic information created using such technologies, you must clearly label it as such; otherwise, lynse reserves the right to take measures including but not limited to adding labels, restricting, or banning the relevant content and accounts.

(2) Permission Scope

If you choose to upload audio from your local device for transcription and summarization, we need to access your storage permission (read) to obtain your audio and video content. ** This is a necessary system permission for local uploading. If you refuse, you will not be able to upload files for transcription and summarization.**

After transcription and summarization are completed, we will access your notification permission to send you notification messages. ** This is a necessary permission for message notifications. If you refuse, you will not be able to receive notification messages.** We adhere to the principle of minimum notification frequency and will only send messages in scenarios related to displaying transcription and summarization progress.

If you choose to use the export function, we need to access your photo library permission (write), storage permission (write), or download permission to save your audio, transcription, and summarization results. ** This is a necessary system permission for the export function. If you refuse, you will not be able to use the export function, but it will not affect your use of other core functions of the Products.**

If you use the sharing function, we need to access your app list access permission to identify target apps available for sharing. ** This permission access is necessary to complete the sharing function. If you refuse, you will not be able to use the sharing function normally, but it will not affect your use of other core functions of the Products.**

1.7 User Preferences

While using the Products, you may choose to set transcription language, industry preferences, and custom vocabulary so that we can remember your preferences and improve the accuracy and relevance of transcription and analysis results. We will collect your transcription language selection, industry preference selection, and custom vocabulary. This information is non-necessary. If you do not provide it, it will not affect your use of transcription and summarization or other functions of the Products.

1.8 Clipboard

When you actively copy or paste text for content input within the Products, we need to access the system's clipboard permission. During this process, we do not read or upload your clipboard information to our servers. ** If you refuse this permission, you will not be able to quickly copy and paste text, but you can still manually enter text and use the Products normally.**

1.9 Biometric Unlock

To fully protect your interests, the Products provide a biometric unlock function (such as fingerprint recognition, facial recognition, etc.) that you may choose to enable in settings. When you enable this function, we need to access the system's biometric-related permissions (the specific names may vary slightly depending on your device's system version, such as "Fingerprint Recognition Permission" or "Face ID Usage Permission"). This permission is used solely to complete local biometric verification for unlocking purposes. We do not upload your biometric information to any server, nor do we collect or store any personal information unrelated to this function in any form. ** If you refuse this permission, you will not be able to use the biometric unlock function, but you can still log in and use the Products normally.**

1.10 Help and Support

To resolve your issues more efficiently and provide service support, the "Help and Support" function within the Products provides the following customer service contact methods:

  1. Phone hotline: When you choose to call the customer service hotline, we need to access the system's phone dialing permission. This permission is used solely to help you quickly initiate a customer service call. We do not collect your call history or address book information, nor do we store dialing data. The customer service hotline is used solely for service communication and not for commercial marketing purposes. ** If you refuse this permission, you will not be able to directly call the customer service hotline from within the Products, but you can still use other customer service contact methods.**

  2. Enterprise WeChat: When you choose to long-press and save the customer service Enterprise WeChat QR code, we need to access the system's photo library permission (write). This permission is used solely to save the QR code locally. We do not read other images or files in your photo library. The QR code serves only as a customer service account identifier, and your communication with customer service is used solely to address your inquiries. ** If you refuse this permission, you will not be able to save the QR code, but you can still use other customer service contact methods.**

  3. You may choose to use the "Share App Logs with the lynse Team" function to export and save your App logs. To save the logs, we need to access your storage permission (write). ** This permission is a necessary system permission for exporting App logs. If you refuse, you will not be able to export App logs normally, which may affect our ability to diagnose and resolve issues you encounter while using the Products.**

1.11 Experience Improvement Program

To provide you with continuous, high-quality service, upon obtaining your consent, we will apply security encryption and de-identification processing to the data you input/provide within the Products, the instructions you issue, the summaries and responses generated by the Products, and your access and usage patterns , and then use them for internal offline analysis. These analyses are solely for the purpose of ** improving your user experience and driving service optimization and iteration.** If you wish to adjust this authorization, you may do so by navigating to "Me" -> "Settings" -> "Preferences" -> "Experience Improvement Program" within the Products. After turning it off, your new data will no longer be used for analysis, but the use of data previously processed based on your authorization will remain unchanged, and adjusting or withdrawing this authorization will not affect your normal use of the Products' core functions. Please also note that if the information you actively provide contains other persons' personal information, you must obtain their lawful authorization before providing it to avoid unauthorized disclosure of their personal information.

Personal Information We Collect Automatically

In compliance with applicable laws and regulations, to ensure the security of your account and to provide you with better and higher-quality services, we collect and use the following information generated during your use of the Products:

2.1 Operations Maintenance and Service Assurance

When you use the App version of the Products, based on the specific permissions granted during software installation and use, including in silent or background running states, we receive and record relevant device information for access volume statistics and fault diagnosis, to safeguard your account and usage security, and to ensure the normal operation of network connections, in-app sharing, and push functions. The specific information includes: ** device serial number, phone hardware model, operating system version, screen parameters, lynse App installation and running status, service provider network ID, network connection type and status, application list,** and ** unique device identifiers (IMEI, Android ID (Android), OAID (Android), GAID (Android), IDFA (iOS), IDFV (iOS), push service identifier OpenID).** This is necessary information for security monitoring, push notifications, and troubleshooting. If you refuse our collection of the above information, we will be unable to perform security monitoring and push notifications for the Products, which may affect account security in certain circumstances.

When you use the Web version of the Products, based on your specific permissions during use, we receive and record relevant device information for access volume statistics and fault diagnosis, to safeguard your account and usage security, and to ensure the normal operation of network connection services. The specific information includes: ** browser and device information (including browser type, language settings, fonts, cache status, etc.) and terminal information (operating system, network type, coarse geographic location, network carrier).** This is necessary information for troubleshooting and security maintenance. If you refuse our collection of the above information, we will be unable to perform security monitoring for the Products, which may affect account security in certain circumstances.

Please be aware that among the above device information, certain third-party SDKs will directly collect part of your device information. You may click to read the Third-Party Information Sharing List to understand the details of third-party SDK collection of your device information.

2.2 Operational Statistics and Product Optimization

When you use the App version of the Products, we automatically collect detailed information about your usage and save it as network log information , including ** lynse App software version number, input box type, text type entered, search query content, network status, manufacturer, phone model, access date and time, and device crash records.** This enables us to compile usage statistics, perform troubleshooting, ensure service stability and network security, and conduct operational analysis to improve and optimize the product interaction experience.

When you use the Web version of the Products, we automatically collect detailed information about your usage and save it as network log information , including ** network log information (IP address, URLs of accessed services, access time and duration), usage behavior information (browsing history, click records, download records, operation logs), and browser type and language settings.** This enables us to compile usage statistics, perform troubleshooting, ensure service stability and network security, and conduct operational analysis to improve and optimize the product interaction experience.

Personal Information We Obtain from Third Parties

We do not obtain your personal information from third parties.

Personal Information We Collect Indirectly

We do not indirectly collect your personal information.

Personal Information Processing Notes

(1) In accordance with applicable laws and regulations, we may process your personal information without your consent in the following circumstances:

(2) In accordance with applicable laws and regulations, we may subject your personal information to technical processing in specific circumstances so that the information cannot precisely identify individual users, and we may conduct anonymized or de-identified statistical analysis of the technically processed information to better enhance product functions and service capabilities.

(3) To help you better understand the details of function-related permission requests, you may click to read the App Permissions List :

Please be aware that enabling any permission constitutes your authorization for us to collect and use the relevant personal information to provide the corresponding service. Once you disable a permission, it is deemed a withdrawal of the corresponding authorization, and we will cease collecting and using your personal information based on that permission and will be unable to continue providing the corresponding service. Your decision to disable a permission does not affect any information processing previously conducted based on your authorization.

III. How We Use Cookies and Similar Technologies

To ensure the normal operation of the Web version of the Products, enhance user experience, and improve our services, we use Cookies and similar technologies on your device.

Cookie Classification and Purpose

Based on their purpose, Cookies can be categorized as follows:

Use of Cookies and Similar Technologies

Cookie Management

You can manage Cookies through your browser settings. Typically, you can find the relevant options in your browser's "Options" or "Settings" menu to clear or block Cookies. Please be aware that if you clear all Cookies or block essential Cookies, you may not be able to use services or features that depend on Cookies.

IV. How We Commission Processing, Share, Transfer, and Publicly Disclose Your Personal Information

Commissioned Processing

To provide you with more comprehensive and higher-quality products and services, we commission third parties (including companies, organizations, and individuals) to process certain personal information on our behalf. For any third party that we commission to process your personal information, we enter into strict data processing agreements that clearly specify the purpose, duration, and method of processing, the types of personal information involved, the security measures, and the rights and obligations of both parties. We supervise the third party's personal information processing activities and require the third party to process your personal information only in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures, and not to process personal information beyond the agreed purposes and methods. If you refuse our third-party partners from collecting the personal information necessary for providing their services during the service delivery process, you will not be able to enjoy the services provided by that third party while using the Products. Our current partners for commissioned personal information processing include:

Sharing

We do 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 statutory requirements: We will share your personal information with third parties in accordance with applicable laws and regulations, for the resolution of litigation disputes, or at the request of administrative or judicial authorities.

(3) Sharing among Affiliates: For collaborative service purposes, your information may be shared among our Affiliates. We will only share your personal information among Affiliates for specific, clear, and lawful purposes as stated in this Policy, and only the information necessary for providing the services. For information shared with Affiliates, we require Affiliates to apply protection measures no less stringent than those stated in this Policy and to strictly comply with applicable laws, regulations, and supervisory requirements. If an Affiliate intends to change the purpose of personal information processing, it will need to obtain your authorization and consent again.

(4) Sharing with authorized partners: Solely to achieve the purposes stated in this Policy, certain of our services may be jointly provided by us and authorized partners. We share certain personal information with our partners to provide better customer service and user experience. We share your personal information only for lawful, legitimate, necessary, specific, and clear purposes, and we share only the personal information necessary for providing the services. Our partners are not authorized to use the shared personal information for any other purpose.

For companies, organizations, and individuals with whom we share personal information, we enter into strict confidentiality agreements requiring them to process personal information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures. They must not process personal information beyond the agreed purposes and methods, and their processing activities must not violate applicable personal information protection and data security laws, regulations, national standards, and other normative documents. In principle, companies, organizations, and individuals with whom we share personal information are not authorized to use the shared personal information for any purpose other than those stated in this Policy.

(5) Third-Party SDKs: Certain functions within the Products are provided by our partner organizations (hereinafter referred to as "SDK Technical Service Providers") in the form of SDK plugins. SDK Technical Service Providers will obtain the corresponding permissions and information necessary to provide you with functions or services. We have conducted security monitoring of all SDKs integrated into this software to ensure that these SDKs only use the basic permissions necessary for their functions or services.

For details, you may click to read the Third-Party Information Sharing List to understand the specifics of how we share your personal information with third parties.

Transfer

We do not transfer your personal information to any third party (including companies, organizations, and individuals) except in the following circumstances:

(1) Transfer with explicit consent;

(2) Transfer required by applicable laws, regulations, legal procedures, or mandatory administrative or judicial requirements;

(3) In the event of a merger, acquisition, or bankruptcy of the Products' service provider, or other circumstances involving a merger, acquisition, or bankruptcy, if personal information transfer is involved, we will inform you of the name and contact information of the receiving party and require the new holder of your personal information to continue to be bound by this Policy. If the receiving party changes the original processing purpose or method, we will require them to obtain your authorization and consent anew.

Public Disclosure

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

(1) With your separate consent or based on your active choice, we may publicly disclose your personal information in specific circumstances;

(2) As required by law, legal proceedings, litigation, or mandatory requirements from government authorities, we may publicly disclose your personal information;

(3) If we determine that you have violated applicable laws or regulations or have seriously violated the Products' relevant agreement rules, or to protect the personal or property safety of the Products' and its Affiliates' users or the public from harm, we may, in accordance with applicable laws or the Products' relevant agreement rules, disclose your personal information, including information about the relevant violations and the measures the Products have taken against you.

Exceptions to Prior Authorization for Sharing, Transfer, and Public Disclosure

In the following circumstances, sharing, transferring, or publicly disclosing your personal information does not require prior authorization from you:

(1) Related to our fulfillment of obligations prescribed by applicable laws and regulations;

(2) Directly related to national security or defense security;

(3) Directly related to public safety, public health, or major public interest;

(4) Directly related to criminal investigation, prosecution, trial, and judgment execution;

(5) For protecting the life, property, or other major lawful rights and interests of you or other individuals, but where it is difficult to obtain the consent of the person concerned;

(6) Personal information that you have voluntarily made public;

(7) Personal information collected from legally publicly disclosed information, such as lawful news reporting or government information disclosure.

Please be aware: Under applicable law, the sharing, transfer, and public disclosure of anonymized personal information does not constitute the external commissioning, sharing, transfer, or public disclosure of personal information. The storage and processing of such data do not require additional notification to you or your consent.

V. How We Protect Your Personal Information

  1. We attach great importance to users' privacy and personal information protection and take reasonable measures to protect users' personal information. Except as otherwise provided by applicable laws and regulations or this Policy, we employ various security technologies and procedures and establish comprehensive management systems to protect your personal information from unauthorized access, use, or disclosure. We do not publicly disclose or reveal users' personal information to third parties without their permission, and we use professional encryption methods for storage and transmission to ensure the security of users' personal information.

  2. You understand and agree that, without disclosing individual users' private information, we have the right to conduct technical analysis of the entire user database, and only anonymized user data that has been analyzed and organized may be used for commercial purposes.

  3. Data Security Measures

(1) We have adopted security protection measures that meet industry standards, including establishing reasonable institutional standards and security technologies to prevent your personal information from unauthorized access, use, or modification, and to avoid data corruption or loss. For example, our web services employ Transport Layer Security (TLS) protocol and other encryption technologies, provide browsing services through HTTPS, and ensure the security of user data during transmission. We employ encryption technologies (TLS, SSL), anonymization or de-identification processing, and protection mechanisms to encrypt and store users' personal information and use isolation technology for data segregation. We manage and regulate the storage and use of personal information through data classification and grading systems, data security management standards, and data security development standards. We restrict access to personal information to only those employees and partners of ours and our Affiliates who have a need to know, through information access confidentiality agreements, and we have established strict access control and monitoring mechanisms. We require all personnel who have access to your personal information to fulfill corresponding confidentiality obligations; failure to do so will result in legal liability or termination of their relationship with us. We have conducted security and privacy protection training courses to enhance employees' awareness of the importance of personal information protection. We have developed and implemented a personal information security incident contingency plan, among other measures.

(2) We have taken all reasonably feasible measures to ensure that no unnecessary personal information is collected. We will retain your personal information only for the period necessary to achieve the purposes stated in this Policy, unless an extended retention period is required or permitted by law.

(3) The internet is not a completely secure environment, and email, instant messaging, and other communication methods with other users are not encrypted. We strongly recommend that you do not send personal information through these methods. Please use complex passwords to help us ensure the security of your account.

(4) While no internet environment is 100% secure, we will make every effort to ensure the security of any information you send to us. If our physical, technical, or management protection facilities are breached, resulting in unauthorized access, public disclosure, tampering, or destruction of information, which causes harm to your lawful rights and interests, we will bear the corresponding legal responsibility.

(5) In the unfortunate event of a personal information security incident, we will, in accordance with applicable laws and regulations, promptly inform you of: the cause of the security incident, the potential harm, the types of personal information involved, the measures we have taken or will take, suggestions and measures you can take to independently prevent and reduce risks. We will promptly notify you of the incident details via email, SMS, phone call, push notification, or other means. When it is difficult to notify each data subject individually, we will issue an announcement through reasonable and effective means. We will also proactively report the handling of personal information security incidents to the relevant regulatory authorities as required. Please be aware that, in accordance with applicable laws and regulations, if measures can effectively prevent harm caused by information leakage, tampering, or loss, we may not notify you.

VI. How We Store Your Personal Information

The Products and related services are provided and used primarily in mainland China. Information collected about you is stored on servers located in mainland China.

Storage Location

In compliance with applicable laws and regulations, information collected about you is stored on servers located in mainland China, with the following exceptions:

Storage Duration

Generally, we will retain your personal information for the period necessary to achieve the processing purposes stated in this Policy while you are using the Products, unless applicable laws, regulations, or national normative documents provide otherwise. Specific regulatory references include:

(1) Retention of network logs for no less than six months as required by applicable cybersecurity regulations.

(2) Retention of product and service information and transaction information for no less than three years from the date of transaction completion as required by applicable e-commerce regulations.

After the above periods have elapsed, or if you proactively request deletion of your personal information or cancellation of your account, we will delete your personal information as soon as possible in accordance with applicable laws and regulations, unless applicable laws, regulations, or national normative documents require retention for a longer period. However, in the following circumstances, we may change the storage period of personal information to comply with legal requirements:

After you discontinue use of the Products, we will cease collecting and using your information, except as otherwise provided by applicable laws, regulations, or supervisory authorities.

When the Products' related services cease operation, we will notify you by sending notifications and announcements, and will delete your personal information retained on our servers within the period required by applicable laws and regulations.

VII. How You Can Manage Your Personal Information Rights

In accordance with applicable U.S. federal and state privacy laws, including but not limited to the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and other applicable state privacy laws, you have the following rights with respect to your personal information:

  1. We ensure that you can exercise the above rights, and we provide you with the relevant operational pathways. Specifically, you may refer to the following steps:

** (1) Access, Correct, Supplement, and Delete Your Personal Information**

You have the right to access, correct, and delete your user information. You can manage your personal information in the following ways:

** (2) Obtain a Copy of Your Personal Information**

You have the right to obtain a copy of your personal information. You may contact us at any time using the method provided in Section XI of this Policy. After verifying your identity, we will provide you with a copy within 15 business days.

** (3) Transfer Your Personal Information**

You have the right to request transfer of your personal information to another service provider where technically feasible. You may contact our customer service as described in Section XI of this Policy. We will process your request within 15 business days.

** (4) Change the Scope of Your Consent or Withdraw Authorization**

You can change the scope of our continued collection of personal information or withdraw your authorization by deleting information, disabling device functions, or other means.

Please be aware that each business function requires certain basic personal information to operate. For the collection and use of additionally collected personal information, you may grant or withdraw your consent at any time. When you withdraw your consent or authorization, we will be unable to continue providing you with the services corresponding to the withdrawn consent or authorization, and we will no longer process your corresponding personal information. However, your withdrawal of consent or authorization does not affect the personal information processing previously conducted based on your authorization.

** (5) Delete Your Account**

You may request deletion of your account registered with the Products at any time. You can do so by navigating in the lynse App to Me -> Profile Avatar -> Delete Account and following the on-screen instructions to complete the deletion.

After you delete your account, we will cease providing you with products and services that require account login. Following account deletion, we will delete or anonymize your relevant personal information in accordance with applicable laws and regulations, unless otherwise required by law or necessary for the performance of legal obligations.

** (6) Responding to Your Requests**

We employ appropriate technical measures to ensure that you can access, supplement, correct, delete, copy, and transfer your personal information, or submit requests through the feedback or complaint channels published in the Products. After receiving your request, we will process it in accordance with our established procedures. For security purposes, we may in certain circumstances require you to verify your identity before processing your request. We will respond to your request within 15 business days. For reasonable requests, we generally do not charge a fee, but for multiple repetitive or unreasonable requests, we may charge a reasonable fee to cover our costs. We reserve the right to refuse requests that are manifestly unfounded, excessively repetitive, require disproportionate technical effort, or pose a risk to the rights and freedoms of others.

If you are unable to access, supplement, correct, delete, copy, or transfer your personal information, change the scope of your consent or withdraw authorization, delete your account, restrict automated decision-making, or disable message notifications, or if you need to access, supplement, correct, delete, copy, or transfer other personal information generated during your use of the Products, or if you believe that we have violated applicable laws or our agreements with you regarding the collection or use of personal information, you may contact us through the official feedback channels of our Products or services.

Please be aware: In the following circumstances, we may be unable to respond to your request:

  1. Where it relates to our fulfillment of obligations prescribed by applicable laws and regulations;

  2. Where it is directly related to national security or defense security;

  3. Where it is directly related to public safety, public health, or major public interest;

  4. Where it is directly related to criminal investigation, prosecution, trial, or judgment execution;

  5. Where we have sufficient evidence that you are acting with malicious intent or abusing your rights;

  6. Where it concerns protecting the life, property, or other major lawful rights and interests of you or other individuals, but it is difficult to obtain the person's consent;

  7. Where responding to your request would cause serious harm to the lawful rights and interests of you or other individuals or organizations;

  8. Where trade secrets are involved.

** (7) CCPA/CPRA-Specific Disclosures**

For purposes of the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

VIII. How We Protect Minors' Personal Information

  1. We attach great importance to the protection of minors' personal information and protect minors' personal information in accordance with applicable federal and state laws, including the Children's Online Privacy Protection Act (COPPA) and other relevant regulations.

  2. We consider anyone under the age of 18 to be a minor. Our Services are not directed to minors, especially children under 14 years of age. If you are under 18, do not use the Services or provide us with any personal information.

  3. If we inadvertently collect personal information from a minor in exceptional circumstances, we will take measures to delete the relevant data as soon as possible.

  4. If you become aware that we may have processed a minor's personal information, please contact us using the contact information provided in Section XI of this Policy, and we will delete the relevant data as soon as possible.

IX. How Your Personal Information Is Transferred Globally

As a general principle, personal information collected in mainland China is stored in mainland China and is not subject to cross-border transfer. If, due to business needs, it is necessary to provide your personal information overseas, we will inform you of the name and contact information of the overseas recipient, the purpose and method of processing, the types of personal information involved, and the methods and procedures for you to exercise your rights with the overseas recipient, and we will only transfer your personal information to a jurisdiction outside the country or region where you use the Products and/or Services, or make your personal information accessible from such jurisdictions, after obtaining your separate consent and meeting the conditions for cross-border provision as required by applicable laws and regulations.

Please be aware that such jurisdictions may have different personal information protection laws and regulations. We will comply with the relevant laws and regulations of the jurisdiction to ensure that your personal information is adequately protected. If such jurisdictions do not have personal information protection laws and regulations, we will make every effort to ensure that your personal information receives protection equivalent to that provided in mainland China.

If you are a user from outside mainland China, we specifically inform you that your personal data will be transferred across borders to servers in mainland China for processing, and we will take all reasonable measures to ensure the security of your personal data.

X. How We Update This Policy

  1. To provide you with better service, the Products and/or Services will be updated and changed from time to time, and we will revise this Policy accordingly. These revisions constitute a part of this Policy. However, without your explicit consent, we will not reduce the rights you are entitled to under this Policy.

  2. After this Policy is updated, we will release the updated version within the App and remind you to read the updated Privacy Policy through app store version release notes or in-app pop-ups, so that you can stay informed of the latest version of this Policy. If you object to the modified or updated content of this Policy, you may access the Products with limited functionality in guest mode, or you may choose to stop using the Products or delete your lynse account. Please be aware, however, that your actions and activities prior to deleting your account or discontinuing use of the Services will remain subject to this Policy.

  3. For significant changes, we will provide more prominent notifications (including but not limited to SMS messages or special prompts on browsing pages to explain the specific changes to this Policy).

The significant changes referred to in this Policy include but are not limited to:

(1) Significant changes in our service model, such as changes in the purpose of processing personal information, the types of personal information processed, or the manner in which personal information is used;

(2) Significant changes in our ownership structure or organizational framework, such as changes caused by business adjustments, bankruptcies, or acquisitions;

(3) Changes in the primary recipients of personal information sharing, transfer, or public disclosure;

(4) Significant changes in your rights regarding personal information processing and how you exercise them;

(5) Changes in the department responsible for personal information security, contact information, and complaint channels;

(6) When a personal information security impact assessment indicates high risk;

(7) Changes made in response to the promulgation or implementation of new policies or laws.

  1. We encourage you to review this Policy periodically while using our Products and/or Services. Specifically, you can access this Policy in the following ways:

XI. How to Contact Us

To better protect your personal information, we have established a dedicated information security and privacy protection department. If you have any questions or suggestions regarding this Policy or your personal information while using the Products, please contact us using the following information:

Email: [email protected]

Address: Room 1901, 19th Floor, Building A, No. 391 Guiping Road, Xuhui District, Shanghai, China 200233

To ensure that we can efficiently process your inquiry and provide timely feedback, you will need to provide proof of identity, valid contact information, and a written request along with relevant evidence. We will process your request after verifying your identity. In principle, we will respond within 24 hours of verifying your identity and provide a substantive reply within 15 days. If you are unsatisfied with our response, particularly if you believe that our personal information processing has harmed your lawful rights and interests, and we are unable to provide a satisfactory resolution after your feedback, you may file a complaint with the relevant regulatory authority, including the California Privacy Protection Agency (CPPA) or the Federal Trade Commission (FTC).

XII. Miscellaneous

Any disputes related to this Policy shall be resolved through friendly consultation between the parties. If the dispute cannot be resolved through consultation, you agree that any such dispute shall be governed by and construed in accordance with the laws of the State of New York, without regard to its conflict of law principles, and the courts of the State of New York shall have exclusive jurisdiction over such disputes.

If any provision of this Policy is held to be invalid or unenforceable by any court of competent jurisdiction, that provision shall be severed from this Policy, and the invalidity of that provision shall not affect the validity of the remaining provisions of this Policy. The remaining provisions of this Policy shall continue in full force and effect.

Website Cookies and Analytics (lynse.ai)

This section applies to the lynse.ai website (including the SparkCard product pages and pre-order checkout flow), in addition to the app sections above.

Cookies and similar technologies. The website stores a minimal set of local entries on your device: your language preference, your cookie consent choice, and — where you have consented — first-party analytics identifiers used to measure how the site performs.

Analytics and advertising pixels. With your consent, the website loads Google Analytics 4, the Meta Pixel, the TikTok Pixel, and Google Ads measurement tags to understand which pages are visited and whether pre-order campaigns are effective. If you choose "Essential only", none of these scripts are loaded and no measurement data is collected. You can change your choice at any time by clearing this site's storage in your browser and reloading the page.

Email sign-ups. If you subscribe to updates or join the pre-order waitlist, we store your email address with our email service provider (Resend) solely to send you the communications you requested. Every marketing email includes an unsubscribe link.

Payments (lynse.ai Pre-orders)

Pre-orders on this website are processed by Stripe, Inc. When you check out, your payment details are collected and processed directly by Stripe under its own privacy policy; we receive only your order identifier, the product purchased, and the email address used for the receipt. We do not see or store your full card number.

We use this information to fulfill your order, send shipping updates, process refunds under our Refund Policy, and provide support. Our shipping and fulfillment partners receive only the information necessary to deliver your order (name, shipping address, and contact details).