Murmur ("Murmur" , "we" or "our" ) fully respects your privacy rights. Murmur is a product of Solstice Technology Co., Ltd. We hereby formulate this Privacy Statement (hereinafter referred to as "this Statement" ) to help you understand how we collect, use, disclose, protect, store and transfer your personal information. Please read this Statement carefully. If you have any questions, please contact us.

This statement applies to our products and services that display or mention this statement.

Personal data refers to various information related to an identified or identifiable natural person recorded electronically or otherwise, excluding information that has been anonymized. We may collect your personal information when you use Murmur products or services and interact with us. The specific types of data collected will vary depending on the products and services you use and your interactions with us. You are not required to provide personal information to Murmur, but in some cases, if you choose not to provide it, Murmur may not be able to provide you with relevant products or services, nor respond to or resolve the issues you encounter.

In the process of providing you with relevant products or services, Murmur may also collect and summarize statistics such as website visits, application downloads, product sales, etc. in order to understand how users use our products and services. For the purpose of this statement, the above statistics are considered non-personal information. We will try our best to separate your personal information and non-personal information and use these two types of data separately. If personal information is mixed with non-personal information, it will still be treated as personal information.

Murmur will only collect and use your personal information for the purposes described in this statement and the privacy notices of each product. The following are examples of the personal information we may collect:

- The data you provide to Murmur

You need to register a Murmur account to enjoy certain features or services. When you register an Murmur account or log in to an Murmur account, we may ask you to provide relevant personal information.

Murmur' products allow you to communicate and share information with others. When you use Murmur products to share content with family and friends, you may need to create a publicly displayed Murmur account profile, including a nickname, avatar, etc. Murmur may collect information you provide about the aforementioned persons, such as name, email address, and phone number. Murmur will take reasonable and necessary measures to ensure the security of the aforementioned communications.

In order to meet the requirements of some jurisdictions for real-name account registration, game anti-addiction systems, etc., Murmur may require you to provide identification issued by the local government or relevant card information that can prove your identity.

- The data Murmur obtained during your use of the service

When you use Murmur products and services, Murmur will collect your device information and information about how you and your device interact with Murmur products and services. Such information includes:

1.    Device and application information. Such as device name, device identifier, device activation time, hardware model, operating system version, application version, software identification code, device and application settings (such as region / language / time zone / font size), etc.

2.    Mobile network information. Such as Public Land Mobile Network Provider ID ( PLMN ), geographic location (cell identification code of the area where the device is located), Internet Protocol ( IP ) address⁠ , etc.

3.    Log information. When you use Murmur' services or view content provided by Murmur, Murmur will automatically collect certain information and store it in logs, such as service access time, number of visits, access IP , event information (such as errors, crashes, restarts, upgrades), etc.

4.    Location information. When accessing certain location-based services, Murmur will collect, use and process the fuzzy or precise location of your device, which may be obtained through GPS , WLAN or the network ID of the service provider . Murmur will ask you whether to enable location-based services. You can choose to turn off the corresponding permissions and refuse to share your location information .

5.    Content you store in the cloud. Content you upload to the cloud will be stored on the server to enable quick access and sharing of the same content between different devices. Content you store in the cloud cannot be accessed or read by anyone without your permission.

- Information from third-party sources

Where permitted by local law, Murmur may also obtain other information about you, your device, or your use of the Services from public or commercial lawful sources, such as when you log in to our Website through a third-party social networking site account, we obtain your information from the third-party social networking site; or when other individuals use our communication services and upload your contact information.

Murmur will only use your personal information when there is a legal basis for doing so. In accordance with applicable local laws, Murmur may use your personal information for the following purposes based on your consent, necessary to perform / enter into a contract between you and Murmur, necessary to protect your or others' legitimate interests, necessary to perform legal obligations, and the legitimate interests of the enterprise:

1.    Murmur products or services you purchased ;

2.    Register an Murmur account so that you can enjoy more diverse features;

3.    Deliver, activate or verify the products and services you request, or make changes to the aforementioned products and services at your request, and provide technical support and after-sales services;

4.    Send you notifications about operating system updates and installations;

5.    Providing you with a personalized user experience and personalized content ;

6.    With your consent or at your request, contact you, send you information about products and services that may be of interest to you, invite you to participate in market research, or send you marketing information;

7.    Conduct internal audits, data analysis and research to analyze business operation efficiency and measure market share to improve Murmur' products and services;

8.    Troubleshoot errors if you choose to send us error details;

9.    Sync and store data you upload or download and data necessary to perform the uploads and downloads;

10. Improve our loss prevention and anti-fraud programs;

11. Comply with applicable local laws and regulations, such as fulfilling e-commerce platform management obligations, or complying with legitimate government requests.

Murmur' websites, online services, emails and advertisements may use local storage technologies such as cookies , pixel tags and web beacons. Murmur treats information collected through cookies and similar technologies as non-personal information. However, if local law considers IP addresses or similar identifiers to be personal information, Murmur will also consider such identifiers to be personal information. In addition, we sometimes combine non-personal information collected through these technologies with other personal information we hold. When we combine data in this way, we will treat the combined data as personal information for the purposes of this statement.

A cookie is a plain text file stored on a computer or mobile device by a web server. The contents of a cookie can only be retrieved or read by the server that created it. Each cookie is unique to your web browser or mobile application. Cookies usually contain identifiers, site names, and some numbers and characters.

Murmur sometimes stores cookies on your computer or mobile device . We enable cookies to improve user experience, including:

1.    Necessary Cookies :

·        Login and verification. When you log in to the website using your Murmur account, with the help of cookies , you can jump directly from one page of the website to another without having to log in again on each page;

·        Storing your preferences and settings. Websites can use cookies to save settings such as your computer’s language, font size, and other browsing preferences;

2.    Analysis Cookies : Statistical analysis. With the help of cookies , Murmur can collect information about your use of our website, such as recording a user's single visit (using session cookies ) or multiple visits (using permanent cookies ).

3.    Advertising Cookies : Interest-based advertising. Murmur uses cookies to collect information about your online activities to discover your interests and provide you with the most relevant advertising;

cookies according to your preferences . You can clear all cookies saved on your computer , and most web browsers have the function of blocking cookies . For more information on how to change your browser settings, please consult the browser provider.

If you clear cookies , you will need to change your user settings each time you visit Murmur' website. Please also note that some of Murmur' services may require the use of cookies , and disabling cookies may affect your use of all or part of the functions of these services .

In addition to cookies , we also use other similar technologies such as web beacons and pixel tags on our websites. Web beacons are usually electronic images embedded in websites or emails that can be used to recognize cookies on your device when you view a web page or email . Pixel tags allow Murmur to deliver emails in a format you can read and allow us to know whether the email has been opened.

Murmur and the third parties we work with use this technology for a variety of purposes, including analyzing service usage (in conjunction with Cookies ) and providing content and advertisements that better meet your needs. For example, an email sent to you by Murmur may contain a click URL that links to the Murmur website content . If you click on that link, Murmur will track the click to help us understand your product and service preferences and improve customer service.

We and the third parties we work with may use other local storage technologies in certain products and services, such as local shared objects (also known as Flash cookies ) and HTML5 local storage. These technologies are similar to the cookies described above , they are also stored on your device and can be used to record certain information about your activities and preferences. However, these technologies may use different devices than standard cookies , so you may not be able to control them using standard browser tools and settings.

Many web browsers have a Do Not Track feature that can issue a Do Not Track request to a website. Currently, the main Internet standards organizations have not established policies to dictate how websites should respond to such requests.

Murmur currently does not support changing the handling of the above cookies based on your selected " Do Not Track " settings or other similar features .

In some cases, Murmur will entrust other companies to process your personal information on behalf of Murmur, such as companies that handle hotlines, send emails, and provide technical support on behalf of Murmur. These companies can only use your personal information to provide services to you on behalf of Murmur.

Murmur will sign a strict entrustment processing agreement or personal information processing clause with the trustee. The trustee is obliged to process the relevant personal information in accordance with this statement and our instructions, and take relevant confidentiality and security measures to ensure the security of personal information.

Sharing means that Murmur provides personal information to other personal information processors, and both parties independently decide the purpose and method of processing in the personal information processing activities. Generally, Murmur will not share your personal information with others, except in the following circumstances:

1.    Sharing with consent: After obtaining your consent, Murmur will share the information within the scope of your authorization with the third party you designate;

2.    Sharing under legal circumstances: Murmur may share your personal information in accordance with laws and regulations, the needs of litigation dispute resolution, or the requirements of administrative and judicial authorities in accordance with the law;

3.    Shared with Murmur' affiliates: Your information may be shared within Murmur' affiliates. We will only share your information within Murmur' affiliates for specific, explicit and legitimate purposes , and will only share information necessary to provide services. For example, in order to avoid duplicate registration when registering an Murmur account, we need to perform a global uniqueness check on the account to be registered;

4.    Sharing with business partners: Murmur may share your account information, device information, and location information with partners and other third parties to ensure the smooth completion of the services provided to you. However, we will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share personal information necessary to provide services.

Murmur will conduct security assessments on sharing behaviors and recipients of personal information, and sign data protection agreements or strict confidentiality agreements with the recipients, requiring them to process personal information in accordance with this statement and take relevant confidentiality and security measures.

In the event of a merger, division, dissolution, acquisition or bankruptcy, if personal information is transferred, we will inform you of the name and contact information of the recipient in advance and require the recipient to continue to process your personal information in accordance with this Statement. If the recipient changes the original processing purpose or processing method, it should obtain your consent again.

Murmur will only publicly disclose your personal information under the following circumstances:

1.    With your consent;

2.    Murmur may disclose your information publicly if required by law, legal process, litigation or public and government authorities .

In short, Murmur will do its best to protect your personal information. However, no measures can be perfect, and no product, service, website, data transmission, computer system, or network connection is absolutely secure.

If a personal information security incident unfortunately occurs, Murmur will inform you in accordance with the requirements of local laws: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to prevent and reduce risks on your own, and remedial measures for you, etc. We will inform you of the relevant situation of the incident by email, SMS, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take reasonable and effective ways to issue an announcement. At the same time, we will also report the disposal of personal information security incidents in accordance with the requirements of local regulatory authorities .

In accordance with local legal requirements, the personal information subject or his/her agent may make a request to Murmur to exercise the above-mentioned personal information subject rights (hereinafter collectively referred to as a "Request" ) .

- Methods and channels for making requests

Requests from the subject of personal information must be made in writing. Even if the requester does not specify the regulations on which the request is based, the request is still valid. Generally speaking, verbal access requests are invalid. If the local country's legislation also recognizes the validity of verbal requests, Murmur will comply with such regulations.

The request of the personal information subject can be made through the Murmur official website. If the personal information subject makes a relevant request through other channels such as the service mailbox, online customer service, etc., we will guide the personal information subject to make a formal request through the aforementioned channels to facilitate communication and feedback on the processing progress and results.

- Validity of request

Most laws require that personal information subjects follow specific requirements when making requests. This statement requires personal information subjects to do the following:

1.    through Murmur' dedicated personal information subject request channel (i.e. Murmur' official website);

2.    Provide sufficient information to Murmur to verify their identity (to ensure that the person making the request is the personal information subject or his/her authorized person);

3.    The request is specific and enforceable.

- Processing period for requests

Murmur will make every effort to ensure that a response is made within the necessary and reasonable time after the personal information subject's access request is made.

1.    No one has the right to access other people's personal information unless they are authorized persons or guardians.

2.    Most laws specify situations where an organization may not provide data to a personal information subject. These situations include the following: providing the data would undermine the fight against terrorism, the personal information subject has repeatedly requested the data, or obtaining and providing the information would consume disproportionate resources.

3.    In principle, Murmur will not provide the following information:

4.    Information about other people - The data that the personal information subject wants to obtain through access request may involve other people other than the personal information subject. Murmur will not provide such information unless the individual involved agrees .

5.    Repeated applications - the requester makes the same or similar request for the same personal information subject, the data has not changed in the past period of time, and Murmur has already provided the data. In this case, Murmur will generally not provide a copy of the data. In addition, Murmur is not obliged to provide information that has already been made public.

6.    Opinions given under confidentiality conditions - If information about the subject of personal information is an opinion given under confidentiality conditions, Murmur is under no obligation to provide such information.

7.    Special Documents - Any special information retained by Murmur will not be disclosed in response to a request for access by the subject of personal information. Generally speaking, special information includes any confidential documents (such as direct communications between clients and their lawyers) and information required to obtain or give legal advice (whether in the course of litigation itself or in court proceedings).

When required by applicable law, you also have the right to withdraw your consent at any time when Murmur processes your personal information based on your consent. However, the withdrawal of consent will not affect the legality and effectiveness of our processing of your personal information based on your consent before the withdrawal, nor will it affect our processing of your personal information based on other appropriate legitimate bases.

We attach great importance to the protection of minors' personal information. Murmur will provide services and protection to minors in strict accordance with national laws and regulations. Parents or other guardians should also take appropriate precautions to protect minors, including supervising their use of various products or services.

Murmur considers anyone under the age of 16 (or the age specified by local law) to be a child. Children may not create their own Murmur account without the consent of their parents or other guardians. We will strictly limit the circumstances of entrusting the processing, sharing, transfer, and public disclosure of children's personal information in accordance with the provisions of laws and regulations. If at any time the guardian needs to access, modify or delete personal information related to the ward, please contact us in the manner described in Chapter 9 " How to Contact Us " . If Murmur finds that it has collected children's personal information without obtaining verifiable parental or other guardian consent in advance, it will try to delete the relevant content as soon as possible.

To ensure a smooth browsing experience, Murmur' websites, products and services may contain links to third-party websites, products and services. Murmur' products and services may also use or provide products or services from third parties. Murmur has no control over such third parties. You can choose whether to access the links, content, products and services provided by third parties.

Murmur cannot control the privacy or data protection policies of third parties, and such third parties are not bound by this statement. Please read and refer to the privacy or data protection policies of these third parties before submitting personal information to them.

Murmur reserves the right to update or modify this Statement from time to time. If we make changes to this Statement, we will publish the latest version of this Statement on our official website. If we make significant changes to this Statement, we may also send you a notification of the changes through different channels, such as posting a notification on our website or issuing a separate notification to you.

If you have any questions, comments or suggestions, please contact us through online customer service.

Generally, we will answer your questions within the time limit specified by laws and regulations. If you are not satisfied with our response, especially if our personal information processing behavior has harmed your legal rights and interests, you can also file a complaint or report to the local privacy protection regulatory department.