Sichuan Liangyou Technology Co., Ltd. (hereinafter collectively referred to as "We") solemnly promise to protect the personal data and privacy of users who use our products and services (hereinafter collectively referred to as "Vgswap"). When you use Vgswap services, we may collect and use your personal data. We hope to explain to you through this privacy policy the corresponding processing rules and other related matters when we collect and use your personal data, so as to better protect your rights and interests.

Before you start using our products and services, please read and understand this Privacy Policy (especially the bold and underlined content) carefully, and ensure that you fully understand and agree before starting use. In addition to this policy, in specific scenarios, we will also explain to you the purpose, scope and use of the corresponding data collection through instant notifications (including pop-up windows, page prompts, etc.), function update instructions, etc. These instant notifications and The function update instructions and so on constitute a part of this policy and have the same effect as this policy. We try our best to explain the professional terms involved in this policy to you in a concise and easy-to-understand manner. If you have any questions, comments or suggestions about the content of this policy, you can contact us through the contact data at the end of this policy. If you do not agree to any of the terms of this privacy protection policy, you should stop accessing and using it immediately.

Your agreement to the privacy policy means that you have understood the functions provided by the app and the necessary personal data required for the function to operate, and have given the corresponding collection and use authorization, but it does not mean that you have separately agreed to enable additional functions and process non-essential personal data. For enabling additional functions, processing non-essential personal data, and processing sensitive personal data, we will ask for your consent separately based on your actual usage.

This policy will help you understand the following:

1. Scope of application
2. How we collect and use your personal data
3. How we use cookies and similar technologies
4. Personal data We May Share, Transfer and Disclose
5. How we protect and store your personal data
6. What rights do you have in relation to your personal data
7. Protection of minors
8. How this policy has been updated
9. How to contact us

The Privacy Policy is translated into other languages, and if there is a discrepancy between the Chinese version and such translations, the Chinese version shall prevail unless otherwise specified.

1. Scope of Application

   1. This privacy policy applies to various products and services provided to you by Sichuan Liangyou Technology Co., Ltd. in the form of websites, clients, applets, and new forms that emerge with technological development. If we and our affiliated companies have separate privacy policies for the products or services they provide to you, the corresponding privacy policies apply to the corresponding products or services.
   2. This Privacy Policy does not apply to Vgswap The platform is linked to other third-party products or services, and your use of these third-party services (including any personal data you provide to these third parties) will be governed by the terms of service and privacy protection policies of these third parties (not this Privacy Policy). Rights Protection Policy), please read carefully the terms of the third party for specific regulations. Please properly protect your personal data and only provide it to third parties when necessary.

2. How we collect and use your personal data

   1. We collect Usage Data about your use of our Platforms and Services. Usage Data may include your IP address, geographic location, browser type and version, operating system, referral source, length of visit, page views, and platform navigation paths. By using cookies we and similar technologies to obtain such data. We collect this data to better understand how you use our Platforms and Services. That is, to monitor and improve our platform, track usage trends, perform business analysis and provide services for the personal benefit of each user.
   2. We collect your account data. Account Data may include your name, business name, identification documents (including your picture), phone number, geographic location and other data you provide during registration and your purchase history. We collect account data to operate our platform, provide our services, ensure the security of our platform and services, and communicate with you. Also to perform a contract between you and us and/or to take steps to enter into such a contract at your request and our legitimate interests, namely to monitor and improve our Platform and Services.
   3. We collect your transactional data. Transaction Data may include your contact details, payment methods, bank account details and transaction details. Transaction data is processed to assist you in the supply or purchase of products and services and to properly record these transactions, to perform a contract between you and us and/or to take steps to enter into such a contract at your request and our legitimate interests, i.e. to Proper Administration of Our Platform and Business.
   4. We have a dedicated fraud detection process to detect and prevent any fraudulent transactions. To ensure timely detection of risks and fraud, effectively prevent fraudulent transactions and improve our fraud detection process,we collect and process various account data, transaction data technical browser and device data, usage data, which allow us to determine Whether the user's behavior suggests suspicious behavior (for example, whether the user is a bot, has tried to trick us in the past, and similar signs associated with fraudulent behavior). In addition to the transaction, account, usage or other data collected, our internal systems may generate other data, such as unique identifiers. The basis for this processing is our legitimate interest to reduce the number of fraudulent transactions and to comply with the requirements of payment service providers and product operators.
   5. We may collect Communication Data in connection with any communication you send to us. Communication data may include communication content and metadata associated with the communication. If communications are made through our Platform, the Platform will generate metadata related to communications made using the Platform Contact Form. Communication data is processed for communicating with you and for record keeping. This is in our legitimate interests, namely the proper administration of our platform and business, ensuring a uniform and high-quality consulting practice, and investigating disputes between you and sellers and our staff.
   6. When you choose to use a third-party account (such as Steam, Google, WeChat, QQ, etc.) to more conveniently register and log in to your Vgswap user account, we will access and collect your express authorization through indirect methods. (Your avatar and nickname data in the third-party account, the specific public data and permissions authorized by different third-party accounts shall prevail) and combine your third-party account with your Vgswap registration account binding. If you refuse to provide the data under the third-party account, you cannot choose to use the third-party account to register and log in.
   7. In addition to the specific purposes for which we may process your personal data as set out in this section, we may process any of your personal data if such processing is necessary to comply with a legal obligation to which we are subject, or to protect Your vital interests or the vital interests of other natural persons.

3. How we use cookies and similar technologies

   1. In order to ensure the normal operation of the Vgswap platform, provide you with an easier access experience, recommend content or advertisements that you may be interested in, etc., we will store a small data file named Cookie on your device. cookies Usually contains identifiers and some numbers and characters. For example, with the help of cookies, websites and clients can store data such as your login data, shopping cart data, referral sources and preferences, and cookies It can also help us count traffic data and analyze the effectiveness of page design and advertisements. We will not use cookies for any purpose other than those stated in this Privacy Policy. You can manage or block cookies according to your preferences, if you block Cookie, you will not be able to use all functions on our platform.
   2. We may also use other similar technologies such as web beacons and pixel tags. For example, emails we sent to you may contain click URL linked to us. If you click this link, we will track down this click, help us to know your preference to products or service and improve customer service.

4. Personal data We May Share, Transfer and Disclose

   1. We may disclose your personal data to your contracting party (supplier, selling user or buying user, as the case may be) to the extent reasonably necessary to perform your contract with these third parties or to comply with legal obligations.
   2. We may disclose your personal data to any member of our group of companies (including our subsidiaries, our ultimate holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this notice. This may include internal management purposes as well as providing/sharing IT within the group service or data center.
   3. We may disclose your personal data to our insurance companies and/or professional advisers to the extent reasonably necessary to obtain or maintain insurance coverage, manage risk, obtain professional advice, or establish, exercise or defend legal claims, whether in In court proceedings or in administrative or out-of-court proceedings.
   4. To the extent reasonably necessary to protect your personal data and comply with our legal obligations, we may disclose your personal data to our anti-fraud, risk and compliance provider.
   5. We may disclose your personal data to our payment service providers. We will only share Transaction Data with our payment service providers to the extent necessary to process your payments, transfers and to handle complaints and inquiries related to such payments and transfers.
   6. We may disclose your personal data where it is reasonably necessary to provide a particular service To other service providers (including server and maintenance providers, email service providers, newsletter delivery service providers, consumer review sites and other service providers). We take all necessary steps to ensure that such subcontractors implement appropriate organizational and technical measures to ensure the security and privacy of your personal data.
   7. In addition to the specific disclosure of personal data set out in this section, we may disclose your personal data if such disclosure is necessary to comply with a legal obligation to which we are subject, or to protect you or another natural person vital interests.
   8. If we need to transfer personal data due to merger, division, dissolution, or bankruptcy, we will inform you of the recipient's name or name and contact data. The receiving party will continue to perform this policy and other statutory obligations. If the receiving party changes the original processing purpose and processing method, it will obtain your consent again.
   9. Persons identified in this section may be established outside the People's Republic of China. If we transfer your personal data to such persons, we will take all necessary and specified steps in the legal act to ensure that your privacy is properly protected, including, where appropriate, entering into standard contractual clauses for data transfers .

5. How we protect and store your personal data

   1. Storage Security

      1. We have adopted reasonable and feasible security protection measures that comply with industry standards to protect your data and prevent personal data from being accessed, publicly disclosed, used, modified, damaged or lost without authorization. For example, we will use technical means including but not limited to firewalls, encryption (such as SSL), de-identification or anonymization processing, etc. to improve the security of personal data, and we will use trusted protection mechanisms to prevent malicious attacks on personal data ; We will implement access control mechanisms to ensure that only authorized personnel have access to personal data.
      2. We have established an advanced data security management system in the industry that centers on data and revolves around the data life cycle, and improves the security of personal data from the dimensions of organizational construction, system design, personnel management, and product technology. We will organize security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal data.
      3. If our physical, technical or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering or destruction of data, resulting in damage to your legitimate rights and interests, we will promptly activate the emergency plan and take reasonable and necessary measures, To minimize the impact on you personally. In the event of a personal data security incident, we will also inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and suggestions for you to prevent and reduce risks independently in accordance with the requirements of laws and regulations. remedial measures. We will notify you by text message, phone call, push notification and other reasonable channels. If it is difficult to notify you one by one, we will issue an announcement in a reasonable and effective manner. At the same time, we will also report the handling of personal data security incidents in accordance with the requirements of the regulatory authorities.
      4. Using Vgswap When conducting online transactions on the platform, you will inevitably disclose your personal data, such as contact data or payment methods, to the counterparty or potential counterparty. In addition, you can also establish communication, exchange data or share content with third parties through our services. Please properly protect your personal data, only provide it to others when necessary, and do not trust in trading through other trading tools, so as to avoid data being stolen or even telecommunications and network fraud.
      5. If you are worried that your personal data, especially your account or password, will be leaked, or if you encounter fraud, please contact the online customer service immediately so that we can take corresponding measures according to your application.

   2. Storage period

      1. We will take reasonable and feasible measures to avoid collecting irrelevant personal data. We will only retain your personal data for the shortest period necessary to fulfill the purposes described in this Privacy Policy, unless you agree to a longer retention period or are permitted by law. After the storage period expires, Vgswap Your personal data will be deleted or technical measures will be taken for anonymization, unless otherwise stipulated by laws and regulations.
      2. This is necessary for our legitimate business interests, such as fraud detection and prevention and enhanced security. if Vgswap To suspend your user account for security and fraud prevention reasons, we may anonymize certain data on the user account to prevent the user from opening a new user account in the future.
      3. As we protect the Platform from accidental or malicious loss and destruction, residual copies of your personal data may not be deleted from our backup systems for a limited period of time.
      4. To comply with local legal obligations. Vgswap may retain some of your data for tax, legal reporting and auditing obligations.

   3. Storage location

      1. The personal data we collect and generate during our operations in the People's Republic of China will be stored in China.
      2. If it is clearly stipulated in the applicable laws, obtaining your separate consent, and the cross-border e-commerce transactions and other types of contracts that you are a party to and the conclusion and performance of contracts, we will, after fulfilling the obligations stipulated by the law, report to the possible Overseas entities provide your personal data, and protect your personal data in accordance with this policy.

6. What rights do you have in relation to your personal data

   1. Access and update your personal data

      1. You can exercise this right by logging into your account.

   2. Delete your user data

      1. We will evaluate according to your deletion request, and if the corresponding regulations are met, we will take corresponding steps to deal with it. When you make a deletion request to us, we may ask you to verify your identity to ensure the security of your account. When you delete data from our service, we may not immediately delete the corresponding data from the backup system due to applicable laws and security technologies, we will safely store your data until the backup can be cleared or anonymized change.

   3. Change the scope of your authorization

      1. You always have a choice whether to disclose personal data to us. Some personal data is used Vgswap Necessary for the Services, but the provision of most other data is at your discretion. You can change the scope of your authorization to continue collecting data or withdraw your authorization by deleting data, turning off device functions, and canceling your account.

   4. Delete account

      1. We provide you with ways to delete your account. You can log in to your account and submit an account deletion application under the conditions stipulated in our terms of service and relevant national laws and regulations. After deleting the account, we will stop providing you with products or services and delete or anonymize your data according to your request, unless otherwise stipulated by laws and regulations. This may also result in you losing access to the data in your account and re-registering your account, please proceed with caution.

   5. Constrained data system automatic decision making

      1. In some business functions, we may only make decisions based on non-manual automatic decision-making mechanisms including data systems and algorithms. If these decisions significantly affect your legal rights, you have the right to request an explanation from us, and we will also provide appropriate remedies.

   6. In response to your request above

      1. For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.
      2. For you or your possible guardians, close relatives and other authorized subjects to make the above requests to us, as well as your relevant personal data rights stipulated by the laws of the People's Republic of China and the applicable laws of other countries and regions, you can contact us through online customer service. We will reply within 15 days.
      3. For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain fee within a reasonable range. For data that is not directly related to your identity, violates local laws and regulations, repeatedly applies for data without reasonable reasons, or requires excessive technical means (such as the need to develop new systems or fundamentally change current practices), or bring legal rights to others We may refuse requests that are risky or impractical.

7. Protection of Minors

   1. Our Platforms and Services are intended for persons over the age of 18 or such other age as may be required by the laws of your respective country, allowing you to be held accountable for obligations arising from a contractual relationship with full capacity to take legal action.
   2. In the process of using Vgswap products and services, we presume that you have the corresponding capacity for civil conduct. If you are a minor, we ask you to ask your parents or other guardians to read this policy carefully, and use our services or provide data to us with the consent of your parents or other guardians.
   3. Any child participating in online activities should obtain the consent of the guardian in advance. If you are a child under the age of 14, please notify your guardian to read this policy together, and seek your guardian's consent and guidance before you use the service or submit personal data. If you click to agree to this policy online, or if you use/continue to use the service or submit personal data, it means that you have obtained the permission of your guardian, and your guardian agrees that we collect, use, Storing, sharing, transferring and disclosing your personal data.
   4. If we become aware that personal data of a person under that age is held in our databases without the consent of a parent or other guardian, we will delete that personal data.

8. How This Policy Is Updated

   1. In order to bring you a better product and service experience, we continue to strive to improve our products, services and technologies. When new services and business processes change, we may update our privacy policy to inform you of specific changes. However, we will not limit your rights under this policy without your explicit consent.
   2. Any changes to this notice will be posted and prominently notified on the Platform, and we may notify you by email if there are material changes.

9. How to contact us

   1. If you have any questions, comments or suggestions about the content of this policy, you can contact us through the Vgswap platform online customer service or support center.
   2. If you are not satisfied with our response, especially if you believe that our personal data processing behavior has damaged your legal rights, you can also seek a solution by filing a lawsuit with the court with jurisdiction in the place where the defendant is domiciled.