"WINDHORSE" is an application provided by Sprocomm Technologies Co.,Ltd. (hereinafter referred to as "we") to provide you with exercise guidance and health services. We know how important your privacy is to you and will do our best to protect it. Please take some time to familiarize yourself with our privacy practices and let us know if you have any questions.

 

We promise you:

 
This Privacy Policy sets out how we collect, use, disclose, process and protect the information you provide to us when using our products and services. If we ask you to provide certain information in order to verify your identity when using our products and services, we will only use this information strictly in accordance with this Privacy Policy and our User Terms and Conditions.
 
This Privacy Policy has been developed with your needs in mind; it is important that you fully understand our personal data collection and use practices and that you are ultimately in control of the personal information you provide to us.

In this Privacy Policy, "personal information" means information by itself or data that identifies a specific individual when linked to other information about that individual to whom we have access. Such personal information includes your telephone number and email address.

By using our products and services, it means that you have read, acknowledged and accepted all the terms described in this Privacy Policy, including any changes we may make at any time. We are committed to protecting the privacy, confidentiality and security of your personal information in accordance with applicable laws, including your local data protection laws. At the same time, we promise all our employees and agents to fulfill these obligations.

In the end, all we want is to bring the best possible experience to our users. If you have any questions about the data processing practices outlined in this Privacy Policy, please contact us at windhorse@sprocomm.com so that we can deal with your particular needs. We are happy to deal directly with your questions.

 
1. What information is collected and how is it used?



1.1 Categories of Information Collected


In order to provide you with our services, we will ask you to provide personal information necessary to provide you with services. If you do not provide personal information, we may not be able to provide our products or services to you.

We collect the following types of information (whether personal or not):

About your information: We may collect and use email address, avatar, nickname, time zone, language.

Mobile phone information: When you use the APP, we need to obtain your mobile phone operating system version, mobile phone brand model, and mobile phone system time.

Location data: When you use location-based program services or functions, we may collect your location data.

Feedback information: When you submit relevant feedback, relevant user feedback logs, contact information and other information will be collected according to your choice.

Device information: When you use an APP to connect to a hardware device, including but not limited to the unique identifier of the device, firmware version, approximate geographic location data (non-personal data) and related function usage statistics (non-personal data) will be sent to the server. The above data collection may also apply to updating your system or software, restoring original factory settings, etc.

Software installation list: When using the login function and more APP push functions, we need to know your software installation list.


2. How do we use cookies and similar technologies


2.1 Cookies


To ensure the proper functioning of our website, we sometimes store small data files called cookies on our computers or mobile devices. 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. With the help of cookies, websites can store data such as user preferences or items in a shopping basket.
 
Most large websites or Internet service providers enable cookies to improve user experience. Cookies allow a website to remember a user's visit (using session cookies) or multiple visits (using permanent cookies). Cookies allow a website to save settings such as the language, font size and other browsing preferences of your computer or mobile device. This means that users do not need to reconfigure user preferences each time they visit. If a website does not use cookies, the website considers the user a new visitor each time the user opens a web page. For example, if you log in to a website and go to another page, the website will not recognize you and you will be logged out again.

We will not use cookies for any purpose other than those stated in this policy. You can manage or delete cookies according to your own preferences. See AboutCookies.org for details. You can clear all cookies saved on your computer, and most web browsers have the function of blocking cookies. But if you do this, you need to change the user settings yourself every time you visit our website. For more information on how to change your browser settings, please visit the following links: <Internet Explorer>, <Google Chrome>, <Mozilla Firefox>, <Safari> and <Opera>.


2.2 Web Beacons and Pixel Tags


Besides Cookie, we also use the same kind of other technologies such as web beacon and pixel tag on the website. For example, emails we sent to you may include click URL linked to our web. If you click this link, we will track down this click, help us to know your product or service preference and improve customer service. A web beacon is usually a transparent image embedded in a website or email. With the help of pixel tags in emails, we can know whether the emails are opened. If you do not want your activities to be tracked down in this way, you can unsubscribe from our mail list at any time.

 
2.3 Do Not Track


Many web browsers have a Do Not Track feature that issues Do Not Track requests to websites. Currently, the major Internet standards organizations have not established policies on how websites should respond to such requests. However, if Do Not Track is enabled on your browser, all of our sites will respect your choice.

 
3. How we disclose your personal data

We will not sell your personal data to third parties. However, we will disclose your personal data in the following circumstances:

 
3.1 Disclosure with explicit consent: After obtaining your explicit consent, we will share your personal data with other parties.

 
3.2 Disclosure based on legal or reasonable grounds: We may disclose your personal data when required by law, legal procedure, litigation or public and government authorities. In some jurisdictions, your personal data will also be disclosed to counterparties if we are involved in reorganization, merger or bankruptcy and liquidation proceedings. We will also disclose your data where there is a legitimate need to do so, for example to enforce our terms and conditions and to protect our customers.


4. How we protect your personal data

 
We take the security of personal data seriously. We adopt industry standard practices to protect your personal data from unauthorized access, disclosure, use, modification, damage or loss. We will take all reasonably practicable measures to protect your personal data. For example, we will use encryption technology to ensure the confidentiality of data; we will use trusted protection mechanisms to prevent data from being maliciously attacked; we will deploy access control mechanisms to ensure that only authorized personnel can access personal data; and privacy protection training courses to enhance employees' awareness of the importance of protecting personal data.


We will take all reasonably practicable steps to ensure that no irrelevant personal data is collected. We will only retain your personal data for as long as necessary to achieve the purposes stated in this policy, unless a longer retention period is required or permitted by law. We will do our best to protect your personal data, but please note that no security measure is impenetrable.

 

5. How to access or modify your personal data


Subject to our terms and conditions, you can manage your personal data, such as your account information, at any time. You should ensure that all personal data submitted is accurate. We endeavor to maintain the accuracy and completeness of personal data and to update such data in a timely manner.

You have the right to access your personal data, subject to certain legal exceptions. Where privacy and information laws in certain jurisdictions differ, we will comply with those laws. If you wish to exercise your data access rights, please notify us by email at windhorse@sprocomm.com. For security reasons, you may need to provide a written request.

You also have the right to delete or amend any personal information we hold about you. We will delete or amend such information at your request. To make such a request, please contact us at windhorse@sprocomm.com. We will refuse to process requests if we have reasonable grounds to believe that the requests are deceptive, unenforceable, or if access is not provided for by local law.

You can send an email to windhorse@sprocomm.com to apply for cancellation of your account. After receiving your application email, we will give you feedback on the guidelines for canceling your account, and you can follow the guidelines to cancel your account. Before you cancel your account, we will verify your account information. You know and understand that the act of canceling your account is an irreversible act. After you cancel your account, we will delete your personal information, unless otherwise stipulated by laws and regulations.


6. Our third party providers and their services

 

Do I have to agree to any third party terms and conditions?
Our Privacy Policy does not apply to products and services offered by third parties. Depending on the products and services you use, it may include third-party products and services, involving analysis statistics, map services, login services, etc., some of which will be provided in the form of links to third-party websites, and some will be provided in the form of SDK , API and other forms of access. When you use these products or services, your information may also be collected. Therefore, we strongly encourage you to take the time to read that third party's privacy policy as you would our own. We are not responsible for, and cannot control how third parties use the personal information they collect from you. Our Privacy Policy does not apply to other websites linked through our Services.

 

· By using Google Fit, you agree to Google Fit's Terms of Service and Privacy Policy: http://www.google.com/policies/privacy

 

·Using Apple Health, you agree to Apple's terms of service and privacy policy: https://www.apple.com/legal/privacy/szh/


·In addition, we have also integrated the following SDKs. When you use these specific products, your information collected by the SDKs, purpose of use and applicable third-party privacy policies are listed below:


AutoNavi Maps, AutoNavi Positioning: You need to call your positioning authority, and will collect your device information, network status, location information, and Wi-Fi information, so as to provide you with maps and positioning services when you are outdoors; privacy Policy: https://cache.amap.com/h5/h5/publish/238/index.html

 
7. How to update this policy


We reserve the right to update or modify this policy from time to time.

 

Sprocomm Technologies Co.,Ltd.

Date Last Updated: April 2023