Privacy Policy
This App is developed, operated, and provided by Xiamen Riyue Xinyu Culture Media Co., Ltd. (hereinafter referred to as "we", "us", or "our"). As a public online interactive platform, this App aims to enable users to discover and connect with third-party advisors to initiate questions, consultations, or requests for specific entertainment and advice services through the platform. We provide this App to you on an "as is" and "as available" basis. The App contains some free features and some paid services settled based on gold coins. The specific billing rules and service content are subject to the display on each page.
We are committed to protecting your personal privacy and information security. This Privacy Policy is intended to clearly and transparently explain to you how we collect, use, store, share, disclose, and protect your personal data during your use of this App, as well as your statutory rights as a data subject.
Please carefully read the entire content of this Policy, paying particular attention to the parts highlighted in bold, italics, or underlined to draw your attention. You may request us to explain all or part of this Policy by sending an email to info@shunshun.tech, or by contacting our Personal Information Protection Officer or customer service.
1. Types and Scope of Personal Data We Collect and Process
To provide you with stable, secure, and business-compliant platform services, SHUNSHUN will collect the following types of personal data under different scenarios when you visit or use this App. We promise that the data collected will not exceed the reasonable scope necessary to provide the product and specific functions:
(a) Image and Multimedia Data: In order to provide you with functions such as custom avatar settings, updating the personal homepage photo wall, and sending pictures during private message communication with advisors, we need to collect the pictures, photos, or image data you actively choose and upload after you actively authorize the camera/album permission. We will not read your phone album or take background photos without your authorization.
(b) Account Registration and Third-Party Authorization Information: When you apply to register as a SHUNSHUN platform user, in order to establish a user account and retain service records for you, you need to use a Google account or an Apple account for one-click login. During this process, we will obtain the email address and third-party account unique identifier (UID) bound to your Google or Apple account through third-party authorization. In addition, you can independently choose and provide your personal nickname, avatar, date of birth (birthday), and gender after registration. Please be aware that your personal nickname, gender, and avatar are public personal profiles and will be publicly displayed to other users and advisors within this App.
(c) Consultation and Communication Record Data: When you initiate a connection with an advisor through the platform (including voice chat, text interaction, etc.), in order to process billing (calculating consumed gold coins/points, connection duration, connection object), ensure transaction security, and conduct platform arbitration in the event of disputes, we need to collect and record:
Your voice communication recording data with the advisor;
The start and end time of each communication, call duration, and communication object (the advisor's platform ID);
Relevant billing transaction records and deduction statements;
The evaluation, star rating, and comment content (evaluation time and specific content) you post about the advisor after each service ends. Please note that your comments are public information displayed to the public in the App. Please do not include any sensitive personal data of yourself or others in the comments. If you unilaterally disclose the personal data of a third party in a comment, you must ensure that you have obtained the legal and explicit authorization of that third party in advance.
(d) Live Stream Interaction Data: When you enter a public or exclusive live stream room and initiate a microphone connection (co-hosting) with the hosting advisor, we need to collect, process, and transmit your real-time voice content, co-hosting duration, timestamp, and the resulting billing data in order to achieve real-time audio and video transmission. Please be aware that the live stream room is a relatively public online environment, and any other users entering the live stream room may hear your voice. Therefore, we strongly recommend that you do not disclose any privacy or sensitive personal data of yourself or others during live streams or co-hosting.
(e) Private Message Chat Data: When you use the private message function of this App to communicate one-on-one with an advisor via text, pictures, or voice, we need to collect, store, and bi-directionally transmit your chat history, sent timestamps, message receiving status, and the corresponding advisor's platform ID to achieve instant information delivery, history query, and platform security maintenance.
(f) Transaction and Payment Data: When you top up in the App to exchange for virtual "gold coins" in order to use paid consultation services, we will collect the internal platform order number, top-up time, order amount,number of gold coins purchased, payment channel (such as Google Play, Apple App Store, local e-wallets, etc.),and top-up status generated during your top-up to ensure that your funds can be accurately credited and the corresponding gold coin balance can be generated. Please note that we do not collect or store your credit card number, bank account password, or e-wallet payment security verification codes and other sensitive financial payment credentials. This information will be directly processed securely by official cooperative third-party payment gateways.
(g) Clipboard Data: In the process of using this App, when you choose to share event links, copy/paste referral codes, or click on specific commands shared by other users to enter corresponding pages, we need to access your device's clipboard data locally to read the passwords, invitation codes, jump event identifiers, or links contained therein. We only perform instantaneous matching and recognition of the clipboard content locally, and will never upload other private content in your clipboard that is unrelated to this App to our server for storage or other purposes.
(h) Device Information and System Logs: To ensure system security, prevent malicious order brushing or multi-account fraud, perform device compatibility adaptation, and optimize the running performance of the App, our system will automatically collect your device hardware and system running log information during your use of this App, including:
Device Hardware Information: Device brand, device model, screen resolution, operating system version,operating system language, device MAC address, device hardware serial number;
Device Unique Identifier: IMSI, IMEI, Android_ID under the Android system; IDFA (Advertising Identifier), IDFV (Vendor Identifier) under the iOS system;
Network and Connection Information: Your IP address, current network connection type (Wi-Fi/4G/5G),and operator information;
Service Log Information: Your login records, page browsing history, system crash logs, click events,software operation exception logs, etc.
(i) Auto-Start and Associated Start Disclosure: To ensure this App can promptly receive and push important private messages, consultation calls, and system notifications when running in the background or after being closed, we have integrated the Easemob Push Notification SDK.
Auto-Start Scenario: After you consent to this Privacy Policy, when new messages or service notifications require timely delivery, the system may trigger the App to auto-start within necessary limits. This is solely used to display notifications and fetch messages; the App will not perform any operations unrelated to the notification service while in the background.
Associated Start Scenario: When you tap a message in the notification bar to navigate to a specific page within the App, or trigger certain in-app functions (such as launching a third-party payment app for top-ups), the App may initiate an associated start of related applications. Such behavior is strictly predicated on your active tap or explicit authorization and is solely intended to serve scenarios you have actively initiated.
Control and Management: You may disable the App’s auto-start or associated start permissions at any time via your device’s Settings > App Management > Permissions. Disabling these permissions may affect your ability to receive timely notifications but will not impact your use of other core functions of the App.
2. How We Use Your Personal Data
We strictly abide by national and regional laws and regulations, and only use the collected personal data for the following purposes under the premise of having clear, reasonable business purposes and a legal processing basis:
2.1 Performance of Contractual Obligations: Used to process your registration application, create and manage your SHUNSHUN account, accurately issue gold coins after you top up, assist you in establishing instant connections with advisors, and ensure the smooth settlement of various paid consultation services.
2.2 Ensuring System Security and Account Anti-Fraud: Used to monitor and identify abnormal login statuses of accounts, troubleshoot device adaptability, and monitor and combat fraud behaviors such as malicious order brushing, illegal top-ups, or money laundering using system vulnerabilities, automated tools, or bugs, so as to maintain platform security and transaction order.
2.3 Internal Statistical Analysis and Product Optimization: Under the premise of anonymizing or de-identifying the collected data (making it impossible to identify you personally), we may use the above data for internal data mining, statistical research, bug fixing, and performance analysis, thereby improving SHUNSHUN's user experience and platform service quality.
2.4 Business Communication and Customer Service: When you encounter problems during use and give feedback to us, we will use your email address, account information, and transaction records to assist you in troubleshooting technical faults, processing order refund applications, and answering policy questions.
2.5 Compliance with Legal Obligations and Cooperation with Law Enforcement: Used to legally use and disclose your data in order to comply with applicable laws, regulations, court judgments, arbitration awards, or to cooperate with the legal investigation requirements of government regulatory agencies and law enforcement departments in various countries.
3. How We Share, Disclose, and Transfer Your Data
We highly respect and strictly protect your personal privacy. We promise that we will never sell, rent, trade, or share your personally identifiable information with any third party for commercial marketing purposes without your explicit written consent or compliance with mandatory legal provisions. We only share, disclose, or transfer your necessary personal data within the following strictly limited scope for the purpose of providing services to you:
3.1 Sharing with Independent Advisors: When you actively initiate a consultation, co-host, or send a private message, the platform must display and transmit your real-time voice, chat text, uploaded pictures, nickname, and gender to the advisor so that the advisor can receive your request, communicate with you, and provide consultation services. Please note that the advisors on the platform are independent contract third parties, and they may be located around the world outside your country.
3.2 Sharing with Our Corporate Affiliates: In order to provide you with cross-regional system maintenance,technical upgrades, and integrated account services, we may share your data with our parent company, subsidiaries,or affiliated entities under common control, provided that they are bound by the strict confidentiality restrictions of this Privacy Policy and the scope of sharing is limited to necessary purposes.
3.3 Sharing with Third-Party Authorized Service Providers (SDK & Gateway Integration): In order to achieve specific functions of this App (such as payment top-up, push notifications, audio and video transmission),our App embeds the software development kits (SDKs) or application programming interfaces (APIs) of third-party partners. These third parties include:
Payment Processors: Including Google Play, Apple App Store, and mainstream local e-wallets and gateways in various regions. We only provide them with the order number, payment amount, and payment channel information necessary to complete the top-up/refund research;
Audio, Video, and Instant Messaging Service Providers: To assist us in real-time distribution and encrypted storage of high-quality audio and video data.
3.4 Legal Compliance and Public Interest Disclosure: Under the following circumstances, we may legally disclose or provide your personal data to third parties without obtaining your prior consent:
Related to our performance of obligations stipulated by laws and regulations;
Directly related to national security and national defense security;
Directly related to public safety, public health, and major public interests;
Directly related to criminal investigation, prosecution, trial, and execution of judgments;
For the purpose of protecting the life, property, and other major legitimate rights and interests of you or other individuals, but it is very difficult to obtain your personal consent;
The personal data collected is disclosed to the public by yourself;
Collecting personal data from legally publicly disclosed information, such as legal news reports, government information disclosure, and other channels.
4. Data Retention, Cross-Border Transfer, and Security Protection Measures
4.1 Data Retention Period: We will only retain your personal data for the minimum period necessary to achieve the purposes described in this Privacy Policy, unless applicable laws have longer mandatory requirements for the retention period of specific data (such as financial transaction records, network log security reviews, etc.). After exceeding the retention period, we will completely delete or permanently anonymize your personal data in accordance with the law.
4.2 Cross-Border Data Transfer: To provide globalized Internet services, your personal data may be transferred to and stored in countries where we, our service providers, or independent advisors are located (including China,Singapore, and your country). No matter where your personal data is processed, we will ensure that it receives a level of security protection equivalent to that of the applicable laws in your country by signing Standard Contractual Clauses (SCCs) and adopting strong encrypted transmission channels.
4.3 Data Security Protection: We adopt industry-standard, lawful technical protection measures and organizational management systems to protect your data security. This includes using the SSL protocol for transmission encryption of sensitive data, strong encryption storage of server data at rest, and implementing strict data access control and security audits for development and management personnel to prevent unauthorized access, tampering, disclosure,or destruction of data.
User Information and Data Security: Our company solemnly commits that, throughout the operation of this software, we will strictly comply with the Cybersecurity Law of the People's Republic of China, the Personal Information Protection Law of the People's Republic of China, and other relevant laws and regulations. We have established a comprehensive data security protection mechanism, are firmly committed to safeguarding user information and other data, adopt rigorous technical measures to prevent data leakage, and guarantee that user information will never be disclosed in violation of any law or regulation.
5. Protections for Minors
5.1 If you are a minor under the age of 18, you must use the SHUNSHUN application and related services only under the guardianship and guidance of your parent or legal guardian, and after obtaining their consent to carefully read and agree to this Agreement. If you use the services without obtaining such consent, your guardian may notify Xiamen Riyue Xinyu Culture Media Co., Ltd. via the official customer service contacts published by the Company. Xiamen Riyue Xinyu Culture Media Co., Ltd. reserves the right to restrict the functionality and usage of the relevant account, including but not limited to browsing, posting information, and interactive communication features.
5.2 Xiamen Riyue Xinyu Culture Media Co., Ltd. attaches great importance to protecting the personal information of minors. Minor users should exercise heightened awareness regarding personal protection when filling in personal information. You must obtain the consent of your guardian and use the SHUNSHUN application and related services correctly under their guidance.
5.3 Minor users and their guardians understand and acknowledge that if you violate laws, regulations, or the terms of this Agreement, you and your guardian shall bear all potential legal liabilities arising therefrom in accordance with the law.
5.4 SHUNSHUN provides a dedicated "Teen Mode" for minors. Guardians should select and enable Teen Mode for minors using the application.
5.5 Special Reminders for Minor Users
(1) Minors should use the SHUNSHUN application and related services under the supervision and guidance of their guardians, utilizing the internet appropriately for learning within reasonable limits, avoiding excessive immersion in virtual cyberspace, and cultivating healthy online habits.
(2) Teen users must adhere to the National Convention on Youth Online Civility.
(3) Utilize the internet for learning purposes and avoid browsing inappropriate information.
(4) Communicate honestly and amicably; refrain from insulting or deceiving others.
(5) Enhance self-protection awareness; do not arrange meetings with online acquaintances arbitrarily.
(6) Maintain network security; do not disrupt network order.
(7) Prioritize physical and mental health; avoid becoming addicted to virtual spaces.
5.6 To better safeguard the privacy rights of minors, Xiamen Riyue Xinyu Culture Media Co., Ltd. specifically reminds users to exercise caution when posting content containing material related to minors. By posting such content, you are deemed to have obtained the consent of the rights holder to display the portrait, voice, and other information of the minor within the SHUNSHUN application and related services, and you permit Xiamen Riyue Xinyu Culture Media Co., Ltd. to use and process such minor-related content in accordance with this Agreement.
5.7 Special Reminders for Guardians
(1) If your ward uses the SHUNSHUN application and related services, you, as the guardian, shall instruct and supervise their registration and usage behavior. If your ward applies to register a SHUNSHUN account, Xiamen Riyue Xinyu Culture Media Co., Ltd. shall have the right to deem that they have obtained your consent.
(2) Your ward may utilize functions such as purchasing products or services while using the SHUNSHUN application and related services. As the guardian, please safeguard your payment devices, payment accounts, and payment passwords to prevent your ward from accessing consumption features via your SHUNSHUN account without your consent.
6. How to Contact Us
If you have any questions about this Privacy Policy or the protection of your personal information, you can contact us through the following means:
Personal Information Protection Officer Contact: info@shunshun.tech
Response Time: Generally, we will respond within 15 days or within the period stipulated by law.
[Privacy Policy - Country-Specific Addenda]
Indonesia
Legal Compliance Basis: This policy and data processing activities strictly comply with the Indonesian Law No. 27 of 2022 on Personal Data Protection ("UU PDP") and its supporting implementation regulations.
Sensitive (Specific) Data: Under Indonesian law, your physical/mental health conditions, sex life, sexual orientation, religious beliefs, and personal financial information that you may disclose when asking questions or communicating with advisors are classified as specific personal data (sensitive personal data). We promise that before processing such specific data, we must obtain your separate and explicit consent (Explicit and Separate Consent) through an independent pop-up prompt or a separate active checkbox on the front end.
Statutory Rights Response Timeline: For your data access rights, correction rights, consent withdrawal rights, or deletion rights exercised as a data subject, we will provide a written reply or complete the processing within 3 to 30 days after verifying your identity (the specific timeline is in strict accordance with the statutory requirements of UU PDP depending on the type of your request).
Minor Compliance: According to Indonesian law, the legal age of majority to independently give personal data consent is 18 years old. If you are under 18 years old, you must read this policy under the supervision and joint participation of your parents or legal guardian, and they shall provide or verify consent on your behalf.
Malaysia
Legal Compliance Basis: This policy and data processing activities strictly comply with the Malaysian Personal Data Protection Act 2010 ("PDPA").
Multi-Language Versions: To meet the compliance requirements of the Malaysian PDPA, this policy is provided in both English and Malay (Bahasa Malaysia) versions. If there is any discrepancy between the two language versions, the English version shall prevail to the extent permitted by law.
Data Access and Correction Timeline: Upon receiving your written request for data access or data correction, we will process it and provide you with a written reply within 21 days. In special circumstances where an extension is required, we will issue an extension notice to you.
Age Restriction: In Malaysia, the legal age to independently authorize the processing of personal data is 18 years old.
Singapore
Legal Compliance Basis: This policy and data processing activities strictly comply with the Singapore Personal Data Protection Act 2012 ("PDPA").
Rights Response Timeline: For your personal data access, correction, or consent withdrawal requests, we will respond and resolve them within 30 days. If it cannot be completed within this period, we will inform you in writing within 30 days of the reason why it cannot be completed and the estimated completion time.
Age Threshold: The legal age of majority for civil compliance and independent contracting in Singapore is generally 21 years old. This App adopts 21 years old as the standard compliance threshold for Singapore users to register independently and authorize personal data processing without guardian consent.
Thailand
Legal Compliance Basis: This policy and data processing activities strictly comply with the Thailand Personal Data Protection Act B.E. 2562 (2019) ("PDPA").
Separate Consent for Sensitive Data: The Thailand PDPA strictly limits the collection of sensitive personal data (including health conditions, sexual preferences, religious beliefs, etc.). Before collecting the above information, we must obtain your explicit consent (Explicit Consent) submitted separately, clearly, and in written or electronic form.
Rights Response Timeline: Unless there are legal grounds for refusal, we will respond to and process your legal requests as a Thai data subject (such as deletion, restriction of processing, withdrawal of consent) within 30 daysfrom the date of receipt.
Minor Restriction: In Thailand, the legal age to independently give consent for personal data processing is 20 years old (unless minor status is terminated by legal marriage). Minors under 20 years old must obtain the co-signed consent of their parents or legal guardian.
Vietnam
Legal Compliance Basis: This policy and data processing activities strictly comply with the Vietnamese Decree No. 13/2023/ND-CP on Personal Data Protection ("PDPD").
Sensitive Data Processing: Vietnamese law defines your political/religious views, personal health status, sexual orientation, and personal financial transaction data as "sensitive personal data". Any collection and processing of such data by us must obtain your clear and independent consent in advance through the "notice and separate consent mechanism" on the App front end.
Ultra-Fast Response Timeline: For legitimate requests made by Vietnamese users to delete personal data, restrict data processing, or correct data, the platform will lawfully complete the processing and provide confirmation to you within 72 hours after receiving the request and verifying the identity.
Age and Child Protection:
For children under 7 years old, data processing must be consented to by parents or guardians on their behalf;
For children from 7 years old to under 16 years old, data processing must obtain the express consent of both the child and their parents or guardians;
Individuals aged 16 years old and above can independently give personal data processing consent under Vietnamese law.
Philippines
Legal Compliance Basis: This policy and data processing activities strictly comply with the Philippines Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA") and its implementing rules.
Sensitive Personal Information: Your health, sex life, religion, or personal financial statements are all classified as "Sensitive Personal Information" under Philippine law. Any processing of such information must be based on your prior, voluntary, and explicit separate written or electronic authorization.
Rights Response Timeline: We will reply in writing and complete the corresponding processing within 30 daysafter receiving your legitimate Philippine data subject request (including access, correction, blocking, or erasure).
Legal Age: The legal age of majority to independently give personal data consent is 18 years old.
Cambodia
Basis of Legal Compliance: This Policy and data processing activities strictly comply with Cambodia's Personal Data Protection Law and relevant regulatory provisions.
Separate Consent for Sensitive Data: Under Cambodian law, processing sensitive personal data involving health status, religious beliefs, personal finances, etc., must obtain your explicit, separate consent (including consent in electronic form) prior to collection.
Time Limit for Rights Responses: In response to legitimate requests for data access, correction, deletion, or withdrawal of consent submitted by Cambodian users, we will provide a written response and complete the processing within 30 days of receiving the request and verifying your identity.
Legal Age: The legal age of adulthood to independently grant consent for personal data processing is 18 years old.