Privacy Policy

The Warmey App (the “App”) is the official online service gateway operated by Warmey. To protect your privacy and improve your experience, Warmey (including its affiliates, “Warmey,” “we,” “us,” or “our”) has prepared this Privacy Policy in accordance with applicable laws and regulations. This Privacy Policy explains how we collect, manage, and protect your personal information. It applies to all services we provide, whether you access them via a mobile device or any other device.

Please read this Policy carefully so you understand how we handle your personal information. This Privacy Policy is an important part of the Warmey Terms of Service and has the same legal effect.

Products and services covered by this Privacy Policy are operated by Warmey and its affiliates. Contact us at service@warmey.com. If you have questions about this Privacy Policy or related matters, you may reach us at any time via that email.

1. How we collect and use your personal information

This Privacy Policy is a foundational document for using our Services and features. Please read it carefully before use and confirm that you fully understand and accept it. We aim to explain related terms in plain language. After we update this Privacy Policy (and notify you in a timely manner), your continued use of our products and/or Services means you agree to the Policy (including updates) and to our collecting, using, storing, and sharing your information as described here.

The data we collect depends on how you interact with us and the choices you make—including your privacy settings and the products and features you use. Data we may collect includes:

• Basic information: such as nickname;
• Location-related information: IP address;
• Online identity information: system account, browser, ISP, email address and related passwords/security questions, platform, timestamps, app identifiers, app version, distribution channel, unique device identifiers, iOS advertising identifier (IDFA), and Android advertising ID;
• Device information: SDK/API/JS versions, MAC address, IMEI, device model, ICCID, manufacturer, OS version, session start/stop times, language/locale, time zone, network status (e.g., Wi‑Fi), disk, CPU, and battery usage;
• Installed application list on the device.

Sensitive personal information is information that, if leaked, illegally provided, or misused, may endanger personal or property safety or easily cause harm to reputation, physical or mental health, or discriminatory treatment. Sensitive personal information covered by this Policy includes:

• Network identity information: account name, nickname, email address, and related passwords and security questions/answers;
• Other information: mobile phone number, software usage records, browsing history, and location information;
• Identity verification materials, where applicable.

You acknowledge and agree that when you register a Warmey account or use our Services, we will record personal information you provide—such as passwords and phone numbers—which is necessary to provide the Services.

To improve user experience, we may also collect other information related to improving the Services—for example popularity of features or browser software information—to continuously improve what we offer.

Before you use the Services, we will guide you to read this Policy and obtain relevant personal information on the basis of your acceptance. If you do not agree to provide personal information, you may be unable to use some or all features and Services.

We collect your personal information only in the following situations:

• When you register a Warmey account, we collect at least nickname, gender, password, password protection options, email address, phone number, and similar information. If you sign in via a linked third party, we may request personal information from that third party; where required information is unavailable from the third party, we may still ask you to provide it. Refusing may affect your use of Warmey or related features. We may also perform identity verification; refusal may result in denial of service.
• When you use location-based features, we may collect location and device information. We will not collect unrelated information for that purpose.
• When you submit feedback, we may collect personal information (such as device or order information) to diagnose issues and send replies.
• When you join marketing activities, we may collect name, mailing address, contact details, bank account, and similar information needed to deliver transfers or gifts. Refusing may prevent us from providing those benefits.
• We may collect device location to provide city-related information; we do not collect unrelated device details for that purpose.
• When you use third-party services within Warmey, you are deemed to allow those third parties to collect order, payment, and similar information as needed to provide their services. Refusing may prevent use of those third-party services.

To protect your information effectively and with your consent, we may de-identify collected data. Without disclosing your personal information, we may analyze and commercially use such processed information.

When you use Warmey to sign in to third-party apps, those third parties may obtain your nickname, avatar, and similar information through Warmey. You may disable this in settings if you prefer not to use that feature.

Where national security or public interest, criminal investigations, protection of life or property in emergencies where timely consent cannot be obtained, information available from lawful public sources, or other circumstances permitted by law apply, we may collect personal information without your prior consent or authorization.

In special cases we may ask for paper identity or supporting documents. Within 30 days of receiving such materials, we will handle them appropriately and notify you in a timely manner.

If we obtain personal information outside the scenarios above, we will seek your express consent again and explain the use case and the scope of information before doing so.

2. Auto-start and associated launch

2.1 Home-screen widgets

On Android devices, home-screen widgets may require auto-start so widget data stays timely and accurate. Disabling that capability may prevent widgets from working properly.

2.2 Push notifications

To receive push broadcasts while the App is closed or in the background, the App may use auto-start and may periodically wake via system broadcasts. This is necessary for those features. Opening a content push after your explicit consent may launch related content; without consent, associated launch will not occur.

2.3 Log collection

To receive client logs while the App is closed or in the background, the App may use auto-start and associated launch via system broadcasts as necessary for logging features.

3. Cookies and similar technologies

Cookies help websites recognize registered users and measure traffic, and are commonly used to determine whether a registered user is signed in. We use Cookie research only to improve service and product quality and optimize experience. If you do not want personal information stored in Cookies, configure your browser to refuse Cookies or notify you when a site sets them. Because our Services rely on Cookies, disabling them may affect access or full use of the Services. When you allow Cookies, you may be asked whether to keep user information for simpler sign-in next time (for example one-tap login).

We use web beacons for the same methods and purposes as Cookies.

To provide better services or products, we use your personal information when:

• required by applicable laws and regulations;
• authorized by you; or
• provided under our Terms of Service or application license agreements.

4. Protection and security measures

We take reasonable efforts to protect personal information we obtain, with dedicated data security responsibilities. To help prevent unauthorized access, copying, modification, transmission, loss, destruction, processing, or use, we have taken and will continue to take the measures below.

4.1 Security measures we take

• Network services use transport-layer security and similar encryption to protect data in transit.
• Personal information is encrypted at rest and isolated where appropriate.
• When using personal information (for example display or association calculations), we apply masking and similar techniques to reduce risk.
• Strict access controls and multi-factor authentication help prevent improper use of data.
• Dedicated technical and security audits, including log and behavior audits.

4.2 Other protective measures

• Data classification and grading, data security management standards, and secure development practices.
• Dedicated security response capabilities for personal information incidents.
• Employee training on security and privacy awareness.

4.3 Security incident notice

If a personal information security incident occurs, we will report to competent authorities as required, investigate promptly, and take emergency measures. We may notify users to change passwords and may reach users by phone, SMS, or other channels, and may communicate on public channels to help stop further disclosure.

Even with reasonable measures and legal standards, we cannot guarantee the security of personal information exchanged through insecure channels. Please take your own precautions—such as regularly updating passwords and not sharing account credentials.

Our personal information protections apply to Warmey platforms. Once you leave Warmey to browse or use other websites, services, or content, we cannot and are not obligated to protect personal information you submit there, whether or not you arrived via our links.

Information leakage risks always exist online. If accidents or force majeure cause a disclosure, we will work to contain the incident and promptly inform you of the cause, our measures, and steps you can take.

5. Sharing, transfer, and public disclosure

5.1 Storage and transmission

We use appropriate security measures to store and protect your personal information against loss, misuse, unauthorized access, disclosure, alteration, or destruction. Personal information is stored on access-controlled servers. Where cross-border transmission is needed, we may continue to use our designated servers by default.

Our business may require transferring personal data to countries outside your region (for example outside the EEA), which may include China or Singapore. We take appropriate steps so recipients protect confidentiality, including measures such as standard contractual clauses. Contact our help center for those terms. Where personal information is transferred overseas, we will inform you and obtain consent as required.

Retention periods vary by sensitivity and applicable law; the minimum retention period is no less than six (6) months where required.

5.2 Use, sharing, and public disclosure

To improve products and services, we may share personal data with vendors or agents who support the purposes in this Privacy Policy—for example analytics providers. We require such parties to protect your data consistently with this Policy.

We will not show personalized ads based on sensitive information (such as health, school, or children’s information). Ads on the platform will indicate how information is used, comply with age ratings, be clearly labeled, and be skippable or closable where provided.

If you provide feedback on warmey.com or in the App, personal information in that feedback is handled under this Policy and may be used to improve products and services.

We may obtain personal information from other sources (email, phone, or fax) and combine it with information collected via our services to improve what we offer.

Only Warmey personnel and necessary third parties with a need to know may access personal information, subject to confidentiality obligations.

Without your permission, we will not share, transfer, or publicly disclose your personal information, except where:

• we have obtained authorization or consent from you or your guardian;
• judicial or administrative authorities require disclosure under legal process;
• we assert claims to protect our lawful rights;
• required by our policies or license agreements with you;
• permitted by law to protect Warmey or the public interest from harm; or
• consistent with agreements between you and another party.

We are not liable for serious consequences such as leaks caused by your own sharing of information.

5.3 Transfer

As our business develops, Warmey or its affiliates may merge, acquire, transfer assets, or enter similar transactions. Your personal information may transfer as part of such a transaction. We will notify you before the transfer.

6. Legal bases for processing

Processing purposes are described above. Legal bases include: performing a contract with you (providing requested services and authenticating access); complying with law (accounting rules, compulsory disclosure); legitimate interests (managing our relationship, securing services, communicating about products); and consent (for example Cookies or sharing for advertising where consent is required).

In some cases you may need to provide personal data so we can deliver full Services and website functionality.

7. How you can manage your personal information

Under applicable law, you may have rights to object to or restrict processing, and to access, correct, delete, or port your personal data.

Where processing is based on consent, you may withdraw consent at any time; withdrawal does not affect processing that was lawful before withdrawal. Submit requests to service@warmey.com.

If your information changes or is inaccurate, please notify us so we can update records. If you believe our processing violates applicable law, you may lodge a complaint with a supervisory authority.

We retain personal data as needed to provide services or products, or as required or permitted by law (for example tax and accounting rules).

You may request account deletion in the App (Home → Profile → Delete account). Before deletion we will verify identity, security status, and commonly used devices. Deletion is irreversible: we will stop collecting your personal information, delete account-related information, and you will no longer receive Services through that account.

After registration and necessary identity verification, you may view, modify, or delete personal information you submitted. For security and identity verification (for example number recovery), some initial registration or verification fields may not be editable.

Request a data export via service@warmey.com. We will verify identity and security status before export.

Protecting your personal information is a priority. You may view, modify, or delete personal information through the mobile client and similar channels.

You may update or correct personal information yourself, or authorize us to do so. We verify identity before making corrections.

Feedback or complaints about this Privacy Policy or related collection, use, storage, or protection practices can be sent by email; we will respond promptly after receipt.

Uninstalling the App can stop further collection of personal information by the App. Disabling certain features may prevent us from providing related Services.

If we terminate services or operations, we will notify you at least thirty (30) days in advance and then delete or anonymize your personal information.

8. Special protection for minors

We take protection of minors’ personal information seriously. If you are under 14, obtain a guardian’s consent before using the Services. If you are 14 or older but under 18, obtain your own or a guardian’s consent before use. Registering an account is treated as confirmation that such consent has been obtained. We protect minors’ personal information in accordance with applicable law and this Privacy Policy.

9. Changes to this Privacy Policy

We may update this Privacy Policy as services and business evolve. Without your express consent, we will not reduce rights you have under the then-effective Policy.

We will publish updated versions on the website and mobile clients and provide notice before they take effect so you can review the latest Policy.

For material changes, we will provide more prominent notice (including email, SMS, in-app message, or on-page alerts) describing the changes.

Material changes include, without limitation:

• significant changes to our service model—purposes of processing, types of personal information, or how information is used;
• significant ownership or organizational changes—business restructuring, bankruptcy, or M&A that change ownership;
• changes to primary parties with whom personal information is shared, transferred, or disclosed;
• significant changes to your rights in personal information processing or how to exercise them;
• changes to the department, contacts, or complaint channels responsible for personal information security;
• a personal information security impact assessment indicating high risk.

Unless otherwise stated in this Policy, and except with your permission or in the cases below, we will not share your personal information with third parties:

• Service providers. Disclosure to personnel who help deliver services (hosting, billing, implementation, storage, and security).
• Legal requirements or rights protection. Where required by law, subpoena, or court order, or where we reasonably believe disclosure is necessary to protect Warmey, third parties, or the public.
• Business transfer / bankruptcy. In a merger, acquisition, bankruptcy, or sale of assets, we may transfer personal information to a successor. Except as otherwise ordered by a court, use and disclosure of transferred information remain subject to this Policy until a new policy is notified; information collected after transfer is subject to the successor’s policy.

When posting on Warmey, comply with applicable rules. If we find illegal content, we may stop transmission, remove it, retain records, and report to authorities as required.

If another user claims your posts disclose identity or privacy, or if commercial messages you post (where permitted) cause harassment, they may ask us to delete the content or take other necessary steps. We will act as required by law.

10. Dispute resolution

Disputes arising from this Policy should first be resolved amicably through negotiation. If negotiation fails, either party may bring an action before a court of competent jurisdiction in accordance with the applicable registration agreement.

Disputes arising from third-party software or technology used by us should be resolved by that third party; Warmey is not responsible and does not provide support for such third-party software or technology. Contact the third party for support. Policies and conditions for using the site and App are also set out in the separate Terms of Service.

If you still have questions about this Privacy Policy, contact us at service@warmey.com—we will respond promptly.

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