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Privacy Policy

Effective Date: Mar 2026. This policy applies to the processing of personal information by Smartware Pte Ltd.

Welcome to Smartware Pte Ltd (or its affiliates) (referring to Smartware Pte Ltd's products and mobile applications (APP), hereinafter referred to as "the Company"). This policy applies to the processing (including collection, use, sharing, transfer, disclosure, etc.) of personal information (as defined below).

We attach great importance to your privacy. To better protect your personal information, we recommend that you carefully read this Privacy Policy ("this Policy") to understand what information we collect from you, how we use it, and how we protect it, so that you can fully understand and agree to its contents. By agreeing to this Policy, you consent to the processing of your relevant information in accordance with this Policy. You should not use the Company's products or services unless you have read and accepted all the terms of this Policy.

This Policy applies to, including but not limited to, personal information that you voluntarily provide in the process of using the Company's services or that is generated due to the use of products/services. However, this Policy does not apply to the use of your personal information by third parties. We encourage you to familiarize yourself with the corresponding privacy policies before providing information to such third parties.

If you have any objections or questions about the terms of this Policy, you may contact us using the details provided in Article 10 - How to Contact Us.

This Policy will help you understand the following: * Related Definitions * How Personal Information Is Collected and Used * How SDK Technology Is Used * How Your Personal Information Is Handled * How Personal Information Is Stored * How We Protect Your Personal Information * How to Manage Your Personal Information * Minor Protection * Amendments and Updates to This Policy * How to Contact Us

1. Related Definitions Personal Information: Various types of information related to identified or identifiable natural persons recorded electronically or by other means, excluding anonymized information. Sensitive Personal Information: Personal information that, once leaked or illegally used, may easily lead to the infringement of personal dignity or endanger personal and property safety. This includes personal biometric information (such as voiceprints) and personal information of children under the age of 14 (inclusive). Anonymization: The process by which personal information is technically processed so that the subject of the personal information cannot be identified and cannot be restored after processing. De-identification: The process of making it impossible to identify or associate personal information with a specific individual without additional information through technical processing.

2. How Personal Information Is Collected and Used We process personal information you actively provide or that is generated during your use of our products/services in accordance with applicable laws and regulations, following the principles of legitimacy, necessity, transparency, and data minimization. We clearly inform you of the purpose and scope of use of such information. If we intend to use your personal information for purposes not specified in this Policy, or to use the collected information for other purposes, we will inform you in advance and obtain your explicit consent.

Types of Information Collected 1. Information Necessary for Basic Business Functions: Required for the normal operation of products/services. If you refuse to provide such information, you may not be able to use core services. 2. Information for Expanded Business Functions: Required for non-core functions. You may choose whether to provide such information. Refusal will not affect your use of basic services.

We may introduce new business features that require additional personal information. In such cases, we will update this Policy and notify you through appropriate means (email, SMS, APP notifications, etc.) and obtain your explicit consent before collection.

Specific Purposes of Use (1) User Registration and Login: When creating an account, you may be required to provide a mobile phone number, email address, username, and password. (2) Audio Playback Functions: We may collect playback history, favorites, and related usage data. (3) Information Display and Personalized Recommendations: We may collect usage logs, browsing behavior, and device information to improve content display and personalize recommendations. (4) Message Notifications: We may send service notifications, security alerts, and promotional information via email, SMS, or APP notifications. You may opt out at any time. (5) Service Improvement: We may conduct surveys or research (using third-party tools) to improve our products and services. Participation is voluntary. (6) APP Permission Instructions: Certain features may require system permissions, including Bluetooth, microphone, location, and phone permissions. Denying such permissions may limit specific functions but will not affect basic services.

3. How SDK Technology Is Used To ensure stable operation and functionality, our applications may embed third-party SDKs. We conduct strict security assessments and require third-party partners to comply with this Policy and applicable data protection laws.

4. How Your Personal Information Is Handled (1) Joint and Entrusted Processing: We may jointly process or entrust third parties to process your personal information for legitimate purposes, subject to strict contractual and security obligations. (2) Transfer: We may transfer personal information in cases such as mergers or acquisitions, subject to your consent or legal requirements. (3) Disclosure: We may disclose personal information only with your consent or as required by law, and with appropriate safeguards. (4) Exceptions to Authorization and Consent: In certain circumstances permitted by law (e.g., national security, public health emergencies, legal obligations), your personal information may be processed without prior consent.

5. How Personal Information Is Stored Storage Location: Personal information is stored within the territory of the People's Republic of China unless otherwise required by law or with your explicit consent. Storage Period: Personal information is retained only for as long as necessary to fulfill service purposes or legal obligations, after which it is deleted or anonymized.

6. How We Protect Your Personal Information We use industry-standard security measures to protect personal information from unauthorized access, disclosure, alteration, or loss. In the event of a data breach, we will notify you and relevant authorities as required by law.

7. How to Manage Your Personal Information You may access, update, correct, or delete your personal information through account settings or by contacting us. You may also withdraw consent or cancel your account, subject to applicable laws and service requirements.

8. Minor Protection Our products and services are not intended for use by minors. We process minors' personal information only with guardian consent and in accordance with applicable laws.

9. Amendments and Updates to This Policy We may update this Policy from time to time. Significant changes will be communicated through prominent notices. Continued use of our services indicates acceptance of the updated Policy.

10. How to Contact Us If you have any questions, inquiries, or complaints regarding this Policy or privacy protection, please contact us: [email protected] or www.mifoglobal.com We will respond within a reasonable timeframe after verifying your identity.

Mifo® is a registered trademark of Smartware Pte Ltd (or its affiliates).