Privacy Policy

Updated: May 14, 2025

Effective Date: May 14, 2025

We take user privacy extremely seriously. When you use our services, we may collect and use your personal information and user data (collectively referred to as “Information”). This Privacy Policy explains how we collect, use, share, store, and manage your Information, as well as how you can exercise your rights related to personal data. Please read this policy carefully, especially the bold or underlined sections. By clicking “Agree,” you confirm that you consent to our collection, use, sharing, storage, and management of your relevant Information in accordance with this policy (including any updated versions).

This policy is closely related to the products and/or services you use. We recommend you read and fully understand it before using our services. We use clear and concise language to explain technical terms for your easy understanding.

Notice for Minors

• If you are a minor under 18, please read this policy with your parent or legal guardian and make decisions under their guidance.
• If you are under 14, you may use this product only after your parent or legal guardian has consented to this Privacy Policy.
• If you are a parent or legal guardian, please ensure your minor child uses this product with your consent.
• If you have any questions, contact us at: vitastrb@galaxesystems.sbs

Table of Contents

I. Collection and Use of Personal Information

II. Use of Cookies and Similar Technologies

III. Sharing, Transfer, and Public Disclosure of Personal Information

IV. Protection of Personal Information

V. Management of Your Personal Information

VI. Protection of Minors’ Information

VII. Updates to This Policy

VIII. Contact Us

I. Collection and Use of Your Personal Information

We collect information you actively provide or automatically generated during your use of our services to provide, optimize, and secure our services.

1. Information Collected

We may collect: device manufacturer, model, storage, operating system and version, screen resolution, IP address, device identifiers (MAC address, IDFA, IDFV), sensor data, and network type. This information helps improve security, prevent fraud, fix app crashes, and optimize performance.

1. Rules for Using Information

• We use collected information only as described in this policy to provide service functions.
• We may anonymize or de‑identify data for analysis and commercial use without further consent.
• You authorize us to use your information while you use our services, unless you delete it or withdraw consent. We stop using and delete your data when you cancel your account.
• We will ask for your explicit consent before using your information for purposes not stated in this policy.

1. Sensitive Personal Information

You may choose not to provide sensitive personal information, but this may affect related functions.

1. Exceptions to Consent

We may collect and use information without consent when:

• Required to fulfill legal obligations;
• Necessary for public health emergencies or to protect life, health, or property in emergencies;
• For public‑interest news reporting or public opinion supervision within reasonable limits;
• Processing information you have lawfully disclosed;
• Necessary for the performance of a contract you request;
• Otherwise permitted by laws and regulations.

If we discontinue our products or services, we will stop collecting information, notify you, and delete or anonymize your personal data.

II. Use of Cookies and Similar Technologies

We use cookies, Flash cookies, and local storage (collectively “Cookies”) on your device. You may disable cookies in your browser settings, but this may limit service functionality.

Cookies are used to:

• Ensure safe and efficient operation of services;
• Provide a more convenient user experience (e.g., remembering login status);
• You may clear cookies in browser settings, but this may disable cookie‑dependent features.

III. Sharing, Transfer, and Public Disclosure of Personal Information

1. Sharing

We do not sell or rent your information. We may share information:

• As required by law, judicial or administrative authorities;
• With your explicit consent;
• To protect our legitimate interests, user safety, or public interests;
• With our affiliates for service provision, under strict confidentiality requirements.

2. Transfer

We do not transfer your information except:

• With your explicit consent;
• In cases of merger, acquisition, or bankruptcy, with the receiving party bound by this policy or required to obtain new consent.

3. Public Disclosure

We disclose information only:

• With your explicit consent;
• As required by law, legal procedures, or government authorities;
• To protect user or public safety.

4. Exceptions to Prior Consent

Sharing, transfer, or disclosure without prior consent is allowed when related to national security, public safety, judicial proceedings, protecting vital interests, information you voluntarily disclosed, legally public sources, public‑interest research, or as permitted by law.

IV. Protection of Personal Information

We use industry‑standard security measures (including SSL encryption, access control, and employee training) to protect your information from unauthorized access, disclosure, use, or damage. No Internet security measure is absolute.

In case of a data breach, we will activate an emergency plan, notify you by email, push notification, or public announcement, and report to regulators as required.

V. Manage, View, or Delete Your Personal Information

You may manage your information through the following methods:

1. Access, correct, delete your personal data via in‑app settings or by emailing us.
2. Withdraw consent by email; we will stop processing related data, but this will not affect prior processing.
3. Request a copy of your personal data; we will provide it within 15 days.
4. Cancel your account by email; after identity verification, we will process your request within 15 days and delete your data permanently.
5. Request explanation of automated decisions that significantly affect your rights.
6. Lodge complaints via email; we will respond within 15 days.

We may decline requests related to national security, public safety, criminal investigations, malicious requests, or trade secrets.

VI. Protection of Minors’ Information

• Users under 18 should use services under guardian supervision.
• Users under 14 may use services only with guardian consent.
• We do not knowingly collect information from minors without guardian consent and will delete such data if discovered.
• We comply with child online protection rules and anti‑addiction systems.

VII. Updates to This Policy

We may update this policy periodically. Updated versions take effect upon posting. We will notify you of material changes. Please check this page regularly.

VIII. Contact Us

If you have questions, comments, or concerns, contact us at:

vitastrb@galaxesystems.sbs

We will respond within 15 days after verifying your identity.

Guidelines for the Protection of Children's Privacy

Updated: October 14, 2025

These Guidelines apply to the processing of personal information of minors under 18. Children under 14 must use our services only with guardian consent.

I. Scope

This Guideline applies to all processing of children’s personal information. It forms part of our Terms of Service together with the Privacy Policy and User Agreement.

II. Collection and Use

We collect only information consented to or voluntarily provided. We do not collect more information than necessary for service functions. We do not proactively obtain children’s information from third parties without authorization.

III. Storage

Children’s personal information is stored only within the People’s Republic of China. We retain data only for the minimum period necessary, after which it is deleted or anonymized.

IV. Security

We use strong security measures to protect children’s data. In case of a breach, we will notify users and regulators as required by law.

V. Rights of Guardians

Guardians may:

• Correct inaccurate information;
• Delete information that is unlawfully processed, excessive, or no longer necessary;
• Withdraw consent;
• Request information access or copies.

VI. Transfer and Disclosure

We do not transfer or disclose children’s information except as required by law or with guardian consent.

VII. Contact Us

For questions about children’s privacy, contact:

vitastrb@galaxesystems.sbs

We will respond within 15 days.