Privacy Policy

Effective Date:2026.05.20

The application operator and application developer for the products and services covered by this Policy are both Shanghai Puying Information Technology Co., Ltd. The Lingxie platform (including the mobile client, hereinafter "Lingxie") is operated and developed by Shanghai Puying Information Technology Co., Ltd. (hereinafter "we").

We fully recognize the importance of data security. This Privacy Policy aims to clarify the rules for us to collect, use, store, share, protect and process your relevant information, as well as define your rights and obligations. By clicking "Agree", completing registration or actually using the Platform Services, you are deemed to have fully read, understood and agreed to all contents of this Policy, including any subsequent revised versions. If you do not agree to any provisions of this Policy, please do not use the Platform Services.

This Policy is a part of the "Service Term" and shall have the same legal effect as the User Agreement. In case of any conflict between this Policy and the User Agreement, the provisions of this Policy shall prevail (unless otherwise mandated by applicable laws and regulations).

I. Definitions and Scope of Application

1.1 Core Definitions

Personal Information: Refers to information recorded in electronic or other forms that can identify a specific natural person individually or in combination with other information, with the specific scope subject to the definition of applicable laws and regulations.

Sensitive Personal Information: Refers to Personal Information that may endanger personal and property safety if disclosed, illegally provided or abused. You warrant that you will only provide such information to us after obtaining legal authorization.

User Data: Refers to all information submitted, generated or retained by you in the course of using the Platform Services (including Personal Information, project data, financial-related data, etc.). You warrant that you have legal ownership and right of disposal over such data and that it does not infringe upon any third-party rights.

Data: Refers to compliant financial market data provided by the Platform to you. The Platform has exclusive legal rights to the collation, compilation and presentation of such data, and you are only granted a limited right of use.

Third-Party Services: Refers to software, interfaces, data or services provided by third parties other than us. Your use of Third-Party Services is unrelated to us.

Self-Hosted Environment: Refers to the environment where you deploy the Platform Services on your own or leased servers. You shall bear full responsibility for the security and compliance of all information in such environment.

1.2 Scope of Application

This Policy applies to all Platform Services provided by us (including official website, client terminal, API interfaces, etc.), but explicitly excludes the following cirumstances:

• Third-party websites or services (including third-party resources accessed through the Platform), whose information processing activities shall be the responsibility of the third party, and we shall not be liable for any responsibility;
• Information independently collected and processed by you in the Self-Hosted Environment. We only provide technical support and shall not be liable for any security or compliance responsibilities;

Special circumstances stipulated by applicable laws and regulations or agreed upon in a separate written agreement between you and us.

You confirm that if you are an enterprise user, you have obtained sufficient authorization from relevant internal personnel to allow us to process their Personal Information generated in the course of using the Platform Services in accordance with this Policy, and you shall bear full responsibility for the legality and validity of such authorization.

II. Information We Collect

We collect information in accordance with the principle of "necessary for providing services". However, you confirm that you shall be solely responsible for the truthfulness, legality and completeness of the information you actively provide, and we have no obligation to verify each item.

2.1 Information You Voluntarily Provide

Account Registration and Identity Verification Information: To register an account, you need to provide an email address, mobile phone number, account password, etc.; enterprise users need to provide enterprise name, unified social credit code, etc.; to meet regulatory or service requirements, you may need to provide identity document information, qualification documents, etc. You warrant that such information is true and valid, and shall immediately notify us of any changes.

Service Usage-Related Information: Configuration parameters, prompts, test data, etc., submitted when using the agent development service; query conditions, subscription requirements, etc., submitted when using the data service; consultation, complaint information, etc., submitted through customer service channels. You confirm that such information does not contain any illegal or infringing content.

Transaction-Related Information: Payment account information, invoice issuance information, etc., provided when purchasing paid services. You agree that such information may be collected by third-party payment institutions and necessary transaction confirmation information may be synchronized to us.

2.2 Information We Automatically Collect

To ensure the normal operation of services, optimize service experience and conduct security prevention and control, we will automatically collect the following information. You may not refuse the collection of such necessary information (otherwise, you will not be able to use the core Platform Services):

• Device and Network Information: Device model, operating system version, unique identifier, browser information, IP address, network type, operator information, etc.;
• Usage Behavior Information: Access time, page browsing records, operation logs, agent running logs, data query records, service usage duration, error logs, etc.;

Information Collected via Cookies and Similar Technologies: We will use technologies such as Cookies and Web Beacons to implement functions such as identity recognition, session management, and preference recording. You can refuse non-essential Cookies through browser settings, but this may result in some functions being unavailable, and we shall not be liable for any responsibility.

2.3 Information Obtained from Third Parties

On the premise of complying with applicable laws and regulations and the agreements with third parties, we may obtain your relevant information from authorized third parties, including but not limited to:

• Identity verification information provided by identity verification service providers;
• Transaction status information provided by payment service providers;
• Compliant financial market data (non-Personal Information) provided by data partners;

Basic information authorized by you when logging in with a third-party account (such as username, avatar).

You confirm that if the information provided by the third party contains errors, omissions or infringements, you shall resolve it with the third party on your own, and we shall not be liable for any responsibility.

2.4 Statement on Information Not Collected

We will not take the initiative to collect information unrelated to the Platform Services, except in the following circumstances:

• Explicitly required to collect by applicable laws and regulations;
• Voluntarily provided by you;

Necessary to ensure the security of the Platform or fulfill compliance obligations.

You confirm that if you provide irrelevant information to us in violation of the above agreements, we have the right to decide to retain, delete or anonymize such information at our discretion, and shall not be liable for any related responsibilities.

2.5 User Content Publication

With respect to your publication and dissemination of content (applicable to content platforms such as information publishing, e-commerce, forums, chat, live audio/video, deep synthesis, generative AI, etc.).

You shall not use new technologies and applications such as deep learning, virtual reality, or generative AI to create, upload, copy, transmit, or disseminate false news or other information prohibited by laws and regulations, or misrepresent synthetic content as natural content. When you publish or disseminate non-factual information created using deep learning, virtual reality, generative AI, or similar technologies, you must clearly label it in a prominent manner. Otherwise, the Platform may take measures against the relevant content and accounts, including but not limited to adding labels, restricting access, or banning accounts.

III. How We Use the Collected Information

We have the right to use the collected information within the following scope without obtaining your additional authorization separately:

3.1 Provide and Maintain Platform Services

• Complete account registration, identity verification, service activation, order processing, payment settlement, invoice issuance, etc.;

Respond to your operation instructions and provide core services such as agent development and data query.

3.2 Optimize and Improve Platform Services

• Analyze device information, usage behavior information, etc., to optimize Platform functions, interfaces, operation processes and improve service stability;

Conduct statistical analysis, technological research and development, new product development, etc., based on the overall user usage data.

3.3 Ensure Platform and Information Security

• Identify and prevent security risks such as fraud, account theft, and cyber attacks;

Detect and troubleshoot system failures, handle violations, and protect the legitimate rights and interests of us and other users.

3.4 Provide Customer Support and Communication

• Respond to your consultations, complaints, answer questions and handle suggestions;

Send you service-related notifications (including account status, order information, policy updates, etc.). You agree that such notifications may be delivered via email, in-site messages, etc.

3.5 Business Analysis and Cooperative Promotion

• Conduct business analysis, market research, industry report generation, etc., based on anonymized and de-identified user data;

Recommend service packages, industry information, etc., that may be of interest to you. You can turn off commercial promotion through Platform settings, but this will not affect the receipt of necessary service notifications.

3.6 Comply with Laws, Regulations and Compliance Requirements

• Respond to investigations or requests from regulatory authorities and judicial organs, and comply with applicable laws and regulations, judicial judgments or arbitral awards;

Protect our legitimate rights and interests, including but not limited to responding to lawsuits, arbitrations, complaints, etc.

3.7 Other Legal Purposes

• If you are an enterprise user, we may use your non-Personal Information data (including agent development cases, industry application data, etc.) for commercial display, cooperative promotion, etc., without obtaining your additional consent;

Other purposes authorized by you. You confirm that written authorization may be made through email, enterprise seal confirmation, etc.

IV. Sharing and Disclosure of Information

We strictly control the scope of information sharing, but in the following circumstances, we have the right to share or disclose your information without obtaining your additional consent (unless otherwise mandated by applicable laws and regulations):

4.1 Sharing with Your Explicit Consent

After obtaining your written consent, we may share information with the third party designated by you. The scope of sharing shall be subject to your authorization, and you shall bear full responsibility for the consequences arising from such authorization.

4.2 Necessary Sharing to Provide Services

• We may share part of your information with third-party partners that provide services to us (such as payment service providers, cloud service providers, identity verification service providers, etc.);
• We will sign strict service agreements and Data Processing Agreements (DPA) with third-party partners. However, you confirm that the third party shall be solely responsible for its information processing activities, and we shall not be jointly and severally liable;

If the third party is an overseas entity, you agree that we shall take measures in compliance with cross-border data transfer rules (such as signing standard contractual clauses), and you do not need to confirm separately.

4.3 Sharing and Disclosure Required by Laws and Regulation

• Comply with applicable laws and regulations, administrative rules, judicial judgments or arbitral awards;
• Respond to legitimate investigations or requests from regulatory authorities, judicial organs and government departments;
• Protect the legitimate rights and interests of us and users, or prevent acts that seriously endanger public interests or the legitimate rights and interests of others;

Maintain the legitimate operation of the Platform and handle violations in accordance with the User Agreement or Platform Rules.

4.4 Sharing in Case of Enterprise Merger, Acquisition or Bankruptcy Liquidation

If we undergo legal acts such as enterprise merger, acquisition, or asset transfer, your information may be transferred to a third party as part of the transaction subject. You agree to such transfer, and the transferee shall assume the rights and obligations under this Policy, and we do not need to notify you separately.

4.5 Use and Sharing of Anonymized or De-Identified Information

We may freely use and share anonymized or de-identified information (information that cannot identify you) with third parties for any legal purposes such as statistical analysis, commercial cooperation, and product development, without obtaining your consent.

V. Storage and Protection of Data

5.1 Data Storage Location

• When you use the public cloud service, information will be stored on servers in Singapore, Hong Kong, China or other compliant regions designated by us. You agree to such storage arrangement and do not need to confirm separately;
• When you use the self-hosted service, the data storage location shall be chosen by you. You warrant that the storage location complies with the requirements of local laws and regulations. You shall bear all risks arising from non-compliant storage locations;

For cross-border data transmission, you agree to the compliance measures taken by us, and you confirm that there is no need to sign a separate agreement related to cross-border data transmission.

5.2 Data Storage Period

• During your use of the Platform Services, we will continuously store your information to ensure the operation of the services;
• If applicable laws and regulations have explicit requirements on the information storage period, store it for the specified period;
• We will continuously store relevant information for the period necessary to resolve disputes or conflicts;

After the expiration of the information storage period, we may choose to delete, anonymize or retain such information (unless otherwise required by applicable laws and regulations), and you have no right to require us to delete it.

5.3 Data Security Protection Measures

• We have adopted reasonable technical and management measures to protect information security (such as encrypted storage, access control, security audit, etc.). However, you confirm that no information transmission and storage technology can guarantee absolute security, and we do not promise that information will not be leaked, lost or tampered with;
• You shall properly keep credentials such as account password, API key, and access rights to the self-hosted environment. You shall bear full responsibility for information leakage or loss caused by improper storage;
• You shall bear full responsibility for data security in the self-hosted environment. We only provide technical support and shall not be liable for any security guarantee responsibilities;

We shall not be liable for any information security incidents caused by third-party attacks, force majeure, improper operation by you or other reasons not attributable to our intent or gross negligence, but we may provide necessary technical assistance.

VI. Your Rights

In accordance with applicable laws and regulations, you enjoy the following rights. However, you confirm that the exercise of rights is subject to the following restrictive conditions:

6.1 Right of Access

You can independently query your Personal Information through the "Personal Center" of the Platform. To query other information, you need to submit a written application to us and provide sufficient identification documents. We have the right to decide whether to provide it based on actual circumstances and may charge a reasonable query fee.

6.2 Right of Correction

If you find that your Personal Information is incorrect or incomplete, you may submit a correction application and relevant supporting materials to us. We will verify and process it within 15-30 working days. If you fail to provide sufficient proof, we have the right to refuse the correction.

6.3 Right of Deletion

You may request the deletion of Personal Information if one of the following circumstances is met, except for the following situations:

• Information required to be retained by applicable laws and regulations;
• Information necessary to resolve disputes, respond to lawsuits or arbitrations;
• Information necessary to ensure the normal operation of the Platform Services;

Other circumstances where we have reasonable grounds to refuse deletion.

You confirm that even if the information is deleted, it will not affect the validity of our previous information processing activities based on legal authorization.

6.4 Right to Withdraw Consent

You may withdraw your consent to the collection and use of information, but after withdrawing consent:

• We will no longer collect and use relevant information based on such consent, but this will not affect the information processing activities completed before;

It may result in some or all Platform functions being unavailable, and you shall not require us to bear any responsibility or compensation for this reason.

6.5 Right to Data Portability

If you request to obtain Personal Information in a structured, machine-readable format or transfer it to a third party, the following conditions must be met:

• Provide sufficient identification documents;
• Prove the ownership of such information;
• Bear relevant technical and service fees;

We have the right to decide whether to provide it based on technical feasibility, compliance requirements, etc., and may limit the scope of transmitted information.

6.6 Right to Account Cancellation

The Lingxie mobile client and Platform provide account registration, login, and cancellation. You may request account cancellation as follows:

(1) In-app self-service cancellation (recommended)

Open the Lingxie app, go to Me → Account Setup, scroll to the Delete Account section at the bottom, tap Delete Current Account, type "注销账号" in the confirmation dialog, and submit. After verification, your account will be cancelled, you will be signed out, and you will no longer be able to log in.

(2) Cancellation by customer service phone

Call 13062703996, state your intent to cancel, and provide your registered mobile number or email for verification. We will process cancellation after identity verification.

(3) Cancellation by customer service email

Send an email to z_song_cma@163.com with the subject "Account Cancellation Request" and include your registered mobile number or email and reason for cancellation. We will verify your identity and reply with progress; cancellation is usually completed within 15 working days (up to 30 working days in complex cases).

You may also submit a cancellation request through the channels listed in Section X (Contact Us), such as info@lingxie.net; we will handle it the same way.

Please back up any data you need before cancellation. After your account is cancelled:

• We will delete your Personal Information or anonymize it (unless otherwise required by applicable laws and regulations);
• Your login credentials, managed avatars, scheduled tasks, knowledge-base indexing, creator synchronization, and other automated programs will be terminated;
• The paid services, packages, Tokens, traffic packs, and unused rights you have purchased will be automatically terminated, and no fees will be refunded;
• Historical messages you sent in one-to-one chats and group chats may remain visible to other participants in their chat history, with the sender shown as a deleted user;
• Orders, payment amounts, usage records, billing ledgers, risk-control logs, and other records necessary for finance, audit, dispute handling, and legal obligations will be retained in accordance with law, with personal identifiers minimized where possible.

Any risks arising after account cancellation (such as data loss) shall be borne by you and have no connection with us.

6.7 Right to Complain and Appeal

If you believe that our information processing activities have infringed upon your rights and interests, you may file a complaint with us, and we will respond within 30 working days. If you are dissatisfied with the response result, you may appeal to the regulatory authority, but you shall not require us to bear any compensation liability on this ground.

VII. Use of Cookies

• We may use Cookies and similar technologies to collect information, including essential Cookies, functional Cookies, analytical Cookies, etc. You confirm that such use is legal;
• You can manage or delete Cookies through browser settings, but disabling essential Cookies may result in being unable to use the Platform Services, and you shall not require us to bear responsibility for this;

We have the right to adjust the types and purposes of Cookies according to business needs without notifying you separately.

VIII. Protection of Minors' Information

• Our Platform Services are not intended for minors. If a minor uses the Platform Services without the consent of their legal guardian, we have the right to immediately terminate the services and delete relevant information, and shall not be liable for any compensation;

If a legal guardian discovers that a minor is using the Platform Services, they may contact us for assistance, but must provide sufficient proof of guardianship; otherwise, we have the right to refuse.

IX. Updates to the Privacy Policy

• We have the right to revise this Policy according to updates to laws and regulations, business adjustments, etc. The revised Policy will be posted on the official Platform website without notifying you separately;
• If the revised Policy involves changes to your core rights and interests, we will notify you to check it through in-site messages or emails. Your continued use of the Platform Services shall be deemed acceptance of the revised Policy;

You confirm that failure to timely check the Policy updates will not affect the validity of the revised Policy, and you shall not claim that the Policy is not binding on you on this ground.

X. Contact Us

• If you have any questions, suggestions or need to exercise relevant rights regarding this Policy, you may contact us through the official website (lingxie.net) or customer service email (info@lingxie.net), and we will respond within 30 working days;
• You confirm that enterprise users or self-hosted users may only consult through their dedicated account managers and shall not request additional service support;

You agree that any disputes related to this Policy shall be resolved through arbitration or litigation, and you shall not require us to bear any rights protection costs.

XI. Miscellaneous

• Any disputes arising from or in connection with this Policy shall first be resolved through friendly negotiation between the parties. If negotiation fails, either party has the right to file a lawsuit with the competent court of the place where our company is registered;
• This Policy constitutes the entire agreement between you and us regarding information protection, replacing all previous oral or written agreements;
• If any clause of this Policy is deemed invalid or unenforceable, it shall not affect the validity of other clauses, which shall remain in full force and effect;

Our failure to exercise or delay in exercising any right under this Policy shall not be deemed a waiver of such right.

XII. Third-Party SDK Directory (Lingxie Mobile Client)

To provide instant messaging, offline push notifications, and audio/video calls, the Lingxie mobile client (Android / iOS) integrates the third-party SDKs listed below. Each SDK may collect device identifiers, network information, push tokens, media you upload, and related data as described in the provider's published privacy rules. This directory supplements the Policy above; if you only use the Lingxie website or self-hosted deployment without the mobile app, the entries below do not apply.

12.1 Push services

Note: Vendor channels are integrated via Alibaba Cloud Mobile Push and OEM SDKs; AppSecret is configured in the EMAS console; the client uses AppId/AppKey only.

12.2 Alibaba Cloud EMAS companion components

Android local AAR components used with mobile push.

12.3 Network and instant messaging

12.4 Device-capability Flutter plugins

These open-source plugins invoke system APIs or local capabilities. Where no separate vendor privacy page exists, processing is described in this Policy.

12.5 Additional iOS integrations

12.6 Not currently enabled

The following are not enabled or not integrated in production builds and are listed for reference only:

• Google FCM (Android): enable.fcm=false; not enabled in production Android builds.
• Amap (Gaode) Map SDK: placeholder webKey; formal SDK not integrated.
• Pure UI/utility libraries: e.g. get, dio, hive — not listed as third-party personal-information SDKs.