MatwingsVenus™ Privacy Service Terms

Preface and Purpose

Welcome to MatwingsVenus™ Platform (the Platform , MatwingsVenus™ , we , or us ). We attach great importance to users’ personal information and privacy security. This Privacy Policy is intended to inform you how MatwingsVenus™ collects, uses, stores, shares, transfers, and protects your personal information, as well as the rights you enjoy regarding your personal information and the ways in which you may exercise such rights. This Privacy Policy shall be used together with the Platform’s Terms of Service, and together they constitute the basis on which you use MatwingsVenus™ services. Please read this Policy carefully before use, especially the key points in bold.

MatwingsVenus™ fully understands the importance of personal information to you and will do its utmost to protect the security and reliability of your personal information. We are committed to maintaining your trust and adhering to the following principles in protecting your personal information: the principle of accountability, the principle of clear purpose, the principle of informed choice and consent, the principle of minimum necessity, the principle of security assurance, the principle of subject participation, and the principle of openness and transparency. At the same time, MatwingsVenus™ promises that we will adopt appropriate security measures in accordance with mature industry security standards to protect your personal information.

Before using our products or services, please carefully read and understand this Privacy Policy (“this Policy”), so that you can better understand our services and make appropriate choices.

Once you check “Agree to the Privacy Policy” or use MatwingsVenus™ services through the registration or login process, you acknowledge the contents described in this Policy. Unless otherwise agreed, the terms used in this Policy shall have the same meanings as those in the MatwingsVenus™ User Agreement.

Scope and Definitions

Scope of Application This Policy applies to all personal information processing activities involved in all services provided to you by MatwingsVenus™ through websites, mobile applications, APIs, SDKs, plug-ins, and other terminals. Services independently provided by third parties shall be governed by their own privacy policies, and this Policy does not apply to the processing activities of such third parties.

Definitions

  • Personal Information: refers to information recorded electronically or by other means that can identify a specific natural person, either independently or in combination with other information, or reflect the activities of a specific natural person, such as name, mobile phone number, email address, third-party account identifier, password, etc.

  • Sensitive Personal Information: refers to information that, once leaked or illegally used, may have a significant impact on personal rights and interests. The Platform will apply a higher standard of protection when collecting or processing such information.

  • Output Content: refers to text, models, reports, data, or other results generated through the Platform services.

How We Collect and Use Your Personal Information Including Cookies and Similar Technologies

Collection Methods

  • Information You Provide : When you register an account, complete a profile, submit feedback, participate in community activities, or use specific features, we may collect your name, email, avatar, contact details, organization information, user preferences, and other information you provide.

  • Automatically Generated Information : When you use our services, we may automatically collect device information (device model, OS version, unique device identifiers), log information (IP address, access time, click records, page dwell time), location information (with your authorization), and data from cookies and similar technologies.

  • Third‑Party Authorized Sources : With your authorization, we may obtain your public profile or behavioral data from third parties (e.g., social login providers, payment platforms) to provide more convenient services.

Purposes of Use We may use your personal information for the following purposes:

  • Account Management : Registration, login, account verification, and security checks;

  • Service Delivery and Maintenance : Providing, maintaining, upgrading, and improving Platform features and products;

  • User Experience Optimization : Analyzing user behavior, personalizing recommendations, and improving products;

  • Customer Service : Handling inquiries, complaints, and user feedback;

  • Compliance and Security : Fraud prevention, platform and user protection, and fulfilling legal obligations;

  • Other Purposes with Your Consent . If we intend to use data for purposes not directly related to the original purpose, we will obtain your consent again.

Data Ownership and Agent Training Commitment Your privacy data remains your property. We do not claim ownership of your personal information, confidential data, or other privacy-related data that you provide, upload, submit, store, or generate through the Platform. We recognize that such data belongs to you or the relevant rights holder. We guarantee that your personal information, confidential data, and other privacy-related user data will not be used to train, fine-tune, or otherwise improve our agent systems, models, or related services, unless we obtain your separate and explicit consent or are otherwise required by applicable laws and regulations.

Cookies and Similar Technologies We use technologies such as cookies, local storage, pixel tags, browser fingerprinting, etc. to maintain login status, prevent risks, enhance user experience, and conduct traffic statistics. You can manage or block cookies in your browser or device settings, but this may affect the normal use of some services or corresponding functions that rely on cookies.

Data Sharing Transfer Storage and Retention

Sharing To achieve service functionality, we may share necessary information with necessary third-party service providers (such as cloud service providers, analytics and security service providers) under contractual constraints and security safeguards. We will not share your personal information with unrelated third parties, except in the following circumstances:

(1) Sharing necessary for fulfilling legal obligations: We may share your personal information as required by laws and regulations, litigation, dispute resolution, or in response to requests made by administrative or judicial authorities in accordance with the law, as well as for other necessary legal obligations.

(2) Sharing with your consent: After obtaining your explicit consent, we will share your personal information with other parties. For example, when you use the talent competency certification service, we will provide your organization with your exam results and certificate information.

(3) Sharing is necessary for the conclusion and performance of a contract to which you are a party.

(4) Other circumstances permitted by laws and administrative regulations.

Transfer and Business Changes In the event of mergers, acquisitions, reorganizations, spin‑offs, or asset transfers, your personal information may be transferred as part of the business. The transferee will continue to be bound by this Privacy Policy or will obtain your consent again if necessary.

Legal and Consent-Based Disclosures After obtaining your explicit consent, or when required by law, judicial or administrative authorities in accordance with the law, we may disclose your personal information in accordance with the law.

Exceptions to Sharing, Transfer, and Disclosure In the following circumstances, we do not need to obtain your consent to share, transfer, and disclose personal information:

Exceptions to prior authorization and consent when sharing, transferring, or disclosing personal information

(1) Necessary for the performance of statutory duties or obligations (such as statutory obligations directly related to national security, national defense security, criminal investigation, prosecution, trial, and execution of judgments, etc.);

It is necessary for responding to public health emergencies or protecting the life, health, and property safety of natural persons under emergency circumstances;

(3) Process your personal information that you have publicly disclosed or that has otherwise been legally made public (such as through legal news reports, government information disclosure, etc.) within a reasonable scope;

(4) Necessary for signing and performing a contract as required by the personal information subject;

(5) Process personal information within a reasonable scope when carrying out activities such as news reporting and public opinion supervision for the public interest;

(6) Other circumstances provided for by laws and administrative regulations.

Storage and Retention We store your personal information in locations and by means that comply with applicable laws and this Policy. Personal information is retained only for the period necessary to achieve processing purposes or as required by law. After the retention period expires, we will delete or anonymize the data. If we cease operating the Platform, we will stop collecting personal information and will delete or anonymize stored data.

Data Security and Your Rights

Security Measures We have implemented industry‑standard technical and administrative safeguards to protect personal information, including but not limited to encryption, access control, audit logging, least‑privilege authorization, identity verification, role‑based access control, server hardening, and secure operations. We maintain internal security policies and incident response plans. If a security incident occurs, we will assess the risk, take remedial actions, and notify regulators and affected users as required by law.

Exceptions to Obtaining Authorization When you use our products and services, we may need to collect and use personal information. In the following situations, we do not need to obtain your authorization:

(1) where necessary for the performance of statutory duties or statutory obligations (for example, statutory obligations directly related to national security, national defense security, criminal investigation, prosecution, trial, and enforcement of judgments);

where necessary to respond to public health emergencies, or under emergency circumstances to protect the life, health, and property safety of natural persons;

(2) where your personal information that you have disclosed on your own or that has otherwise been lawfully disclosed is processed within a reasonable scope (such as through lawful news reports, government information disclosure, or other channels);

(3) where necessary for the conclusion and performance of a contract at the request of the personal information subject;

(4) where personal information is processed within a reasonable scope for public interest activities such as news reporting and public opinion supervision;

other circumstances provided by laws and administrative regulations.

User Rights To the extent permitted by law, you enjoy the following rights:

  • Access and Correction : Query, view, and correct your personal information;

  • Deletion : Request deletion of personal information where permitted by law and business needs;

  • Withdrawal of Consent : Withdraw consent for specific processing activities at any time; withdrawal does not affect processing already carried out based on prior consent;

  • Account Cancellation : Request account cancellation; after verification we will process the request and delete or anonymize related information within legal limits;

  • Obtain a Copy : Request a copy of the personal information we hold about you;

  • Complaints and Reports : Lodge complaints if you believe our processing infringes your privacy rights. To exercise these rights, please contact us using the contact information at the end of this Policy. We will respond within a reasonable timeframe and may require identity verification to protect your information.

Minors Protection Policy Changes and Contact

Minors Protection If you are under the legal age, you should use the Platform under the guidance of a guardian and obtain guardian consent before submitting personal information. For children under 14 years old, we will collect and use personal information only after obtaining verifiable parental or guardian consent and only to the extent necessary and permitted by law. If we discover we have inadvertently collected a minor’s personal information without verifiable consent, we will promptly delete or anonymize it.

Policy Changes and Notification We may update this Privacy Policy due to business development, legal or regulatory changes, or security needs. For material changes, we will notify you via website announcements, in‑app messages, or email in advance. If you do not agree with the updated Policy, you may stop using the services; continued use after the update constitutes acceptance.

Material changes under this Policy include:

  1. significant changes to our service model, such as the purpose of processing personal information, the types of personal information processed, or the manner in which personal information is used;

  2. significant changes in our ownership structure or organizational structure, such as changes in ownership caused by business adjustments, bankruptcy, mergers, or acquisitions;

  3. changes to the main recipients of personal information sharing, transfer, or public disclosure;

  4. significant changes to your rights regarding personal information processing and the ways in which such rights may be exercised;

  5. changes to the department responsible for personal information security, contact methods, or complaint channels;

  6. circumstances where the personal information security impact assessment report indicates a high risk.

Contact Information If you have questions, comments, requests, or complaints regarding this Policy, please contact us at:

  • Email : ruofan.xiong@matwings.com

  • Contact Address : Shanghai Tianwu Technology Co., Ltd., 16th Floor, Building 1, No. 58 Yuanmei Road, Minhang District, Shanghai

We will handle your request promptly and respond within a reasonable period. You may also lodge complaints with relevant supervisory authorities or seek legal remedies.

Effective Date and Other Provisions

This Privacy Policy shall take effect from the date you register, log in to, or otherwise use the services of the MatwingsVenus™ Platform. If any provision of this Policy is determined to be invalid or unenforceable, the validity of the remaining provisions shall not be affected. MatwingsVenus™ reserves the right to interpret and revise this Policy within the scope permitted by law.

Copyright This Privacy Policy is the property of MatwingsVenus™ Platform .