Ciro Privacy Policy

Last Revised: 2025.11.5

Ciro Team, the development team responsible for Ciro, places the utmost importance on safeguarding your privacy. This Privacy Policy is crafted to clearly inform you about how we handle, store, and utilize your personal information, empowering you with complete transparency and control over your data. By accessing or using Ciro, you acknowledge and consent to the practices detailed in this document.

Ⅰ. Introduction to Data Protection Commitment

At Ciro Team, we adhere to global data protection principles to ensure your personal information is treated with the highest level of care. Our primary goal is to balance the delivery of a seamless, personalized Ciro experience with the protection of your privacy rights. This Policy outlines the specific ways we collect, use, and protect your data, as well as your rights regarding that data.

Ⅱ. Data Security Protocols We Implement

Protecting your personal information from unauthorized access, loss, or misuse is a top priority for Ciro Team. We have established comprehensive security measures to safeguard your data throughout its lifecycle:

· End-to-End Encryption: Sensitive information, including account credentials and personal details, is encrypted both when transmitted between your device and our servers and when stored on our systems.

· Restricted Access Controls: Only authorized Ciro Team personnel, who are bound by strict confidentiality obligations, have access to your personal data. Access is granted solely for job-related purposes.

· Regular Security Audits: We conduct frequent assessments and updates of our security infrastructure, including firewalls, intrusion detection systems, and data storage protocols, to address emerging threats and vulnerabilities.

· User Responsibility Reminder: While we maintain robust security standards, we encourage you to use a unique, strong password for your Ciro account and avoid sharing your login credentials with others to further protect your data.

Ⅲ. Types of Information We Gather

Ciro Team collects information from you in two main ways: information you actively provide, and information automatically collected as you use the app.

1. Information You Voluntarily Provide

When you interact with Ciro—such as creating an account, customizing settings, or reaching out to our support team—you may share the following personal information:

· Account-related details: Full name, unique username, and email address (required to set up, verify, and manage your Ciro account).

· Preference data: Choices related to app notifications, privacy settings, content preferences, and other customizations you select to tailor your Ciro experience.

· Support-related information: Details you provide when contacting our support team (e.g., issue descriptions, screenshots) to help resolve your queries.

2. Automatically Collected Information

As you use Ciro, our systems automatically collect certain data to ensure the app functions properly, improve its performance, and deliver personalized features. This includes:

· Device information: Details about the device you use to access Ciro, such as device model, operating system version, hardware specifications (e.g., processor, memory), and unique device identifiers (e.g., IMEI, UDID) to optimize app compatibility.

· Location data: If you enable location permissions in your device settings, we may collect either approximate location data (derived from your IP address) or precise location data (using GPS, Wi-Fi, or cellular signals) to provide location-based features (e.g., region-specific content). You can disable location permissions at any time through your device settings.

· Usage analytics: Data about how you interact with Ciro, including which features you use most frequently, the duration of each app session, the time and date of your usage, and any errors or crashes you encounter. This data helps us identify areas for improvement and develop new features that align with user needs.

3. Tracking Technologies

We use cookies, web beacons, and similar tracking tools within Ciro and on our associated websites. These tools help us:

· Analyze user behavior to understand how people interact with the app.

· Remember your preferences (e.g., login status, notification settings) for a more seamless experience.

· Measure the effectiveness of app updates and marketing efforts (if applicable).

· You can manage cookie preferences through your device or browser settings, though disabling certain cookies may affect the functionality of Ciro.

Ⅳ. How We Utilize Your Information

Ciro Team uses the information we collect for specific, legitimate purposes that enhance your experience with Ciro and ensure the app operates securely. These purposes include:

· Personalization: Tailoring Ciro’s content, features, and interface to match your preferences and usage patterns (e.g., recommending features you may find useful based on past interactions).

· App Improvement: Using usage analytics and feedback to identify bugs, optimize existing features (e.g., reducing load times), and develop new tools or content that address user needs.

· Security and Fraud Prevention: Protecting your Ciro account from unauthorized access, detecting and mitigating fraudulent activities (e.g., account takeovers), and ensuring the safety of all users and our systems.

· Customer Support: Using the information you provide (e.g., issue details, account information) to respond to your queries, resolve technical problems, and provide efficient support.

· Compliance with Legal Obligations: Handling your data in accordance with applicable laws and regulations (e.g., data protection laws, tax requirements) and responding to lawful requests from government authorities.

Critical Note: Ciro Team will never sell, rent, or lease your personal information to third parties for marketing purposes.

Ⅴ. Your Privacy Rights and How to Enforce Them

Under applicable data protection laws, you have specific rights regarding your personal information held by Ciro Team. These rights include:

· Right of Access: You can request a copy of the personal information we have stored about you, including details about how we use and share that data.

· Right to Rectification: If any of your personal information in your Ciro account is inaccurate or incomplete, you have the right to request that we correct or update it.

· Right to Erasure (Right to be Forgotten): You can ask us to delete your personal information, except in cases where we are legally required to retain it (e.g., to comply with tax laws or resolve ongoing disputes).

· Right to Restrict Processing: In certain circumstances (e.g., if you dispute the accuracy of your data), you can request that we limit how we process your personal information until the issue is resolved.

· Right to Control Communications: You can choose which types of notifications (e.g., marketing updates, app alerts) you receive from us, or opt out of non-essential communications entirely, through your Ciro account settings.

To exercise any of these rights, please contact our privacy team at tanghaitian678@sina.com. We will respond to your request within a reasonable timeframe (as required by law) and may ask for additional information to verify your identity before processing your request.

Ⅵ. Data Retention and Erasure Practices

Ciro Team retains your personal information only for as long as it is necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law. The retention period for each type of data is determined by:

· The purpose for which the data was collected (e.g., account information is retained while your Ciro account is active; support-related data is retained for a reasonable period after resolving your query).

· Legal obligations (e.g., we may retain certain data to comply with tax, employment, or consumer protection laws).

· Once the retention period expires, or if you request the deletion of your data, we will either:

· Permanently delete your personal information from our systems and records.

· Anonymize the data (so it can no longer be linked to you) for use in aggregate analytics or app improvement, without further reference to your identity.

If you delete your Ciro account, we will initiate the erasure of your account-related data within a reasonable timeframe, except where legal retention requirements apply.

Ⅶ. Circumstances Where We Share Your Information

Ciro Team does not sell your personal information to third parties. However, we may share your data in the following limited circumstances, always ensuring that third parties adhere to strict data protection standards:

· With Trusted Service Providers: We may share your information with third-party vendors or partners who perform services on our behalf, such as cloud storage providers (to store your data securely), analytics firms (to help us analyze app usage), or customer support platforms (to assist with resolving your queries). These third parties are contractually obligated to protect your data and only use it for the specific services they provide to Ciro Team.

· For Legal Compliance: We may disclose your information if required by law, regulation, or legal process (e.g., a court order, subpoena) or to respond to lawful requests from government authorities.

· To Protect Ciro and Its Users: We may share your data if we believe it is necessary to protect the safety, security, or integrity of Ciro, Ciro Team, or our users (e.g., to investigate fraud, prevent harm, or address violations of our Terms of Service).

· In the Event of a Business Transition: If Ciro Team undergoes a business transition, such as a merger, acquisition, or sale of all or part of its assets, your personal information may be transferred to the new owner or entity. In such cases, we will notify you of the transfer through a prominent notice in Ciro or via email (using the address associated with your account) before the transfer takes place, and ensure the new owner complies with this Privacy Policy.

Ⅷ. Protection of Children’s Privacy

Ciro is not intended for use by children under the age of 17, and Ciro Team does not knowingly collect, use, or store personal information from children under 17. If we become aware that we have inadvertently collected personal information from a child under 17 without the verifiable consent of a parent or legal guardian, we will take immediate steps to delete that information from our systems.

Parents or legal guardians who believe their child under 17 has provided personal information to Ciro may contact us at tanghaitian678@sina.com to request the deletion of such data. We may ask for additional information to verify your relationship to the child before processing the request.

Ⅸ. International Transfer of Data

Ciro Team serves users worldwide, and as a result, your personal information may be transferred to, stored in, or processed in countries outside of your country of residence—including countries where data protection laws may differ from those in your home country. By using Ciro, you acknowledge and consent to the transfer of your data to these international locations.

Ciro Team ensures that all international data transfers comply with applicable data protection laws. We use safeguards such as:

· Transferring data to countries that have been deemed to provide an adequate level of data protection by relevant authorities (e.g., the EU’s “adequacy decisions”).

· Using standard contractual clauses (approved by data protection regulators) with our international service providers to ensure your data is protected.

Ⅹ. Updates to This Privacy Policy

Ciro Team may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological advancements. When we make updates:

· We will post the revised Policy on our official website (if applicable) and within the Ciro app, with a new “Last Revised” date at the top.

· For significant changes (e.g., changes to how we collect or use your data), we will notify you through a prominent notice in the app (e.g., a pop-up alert) or via email (sent to the address linked to your Ciro account) at least 7 days before the changes take effect.

Your continued use of Ciro after the effective date of the revised Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed about how we protect your privacy.

Ⅺ. Contact Us

If you have any questions, concerns, or feedback about this Privacy Policy, or if you wish to exercise your privacy rights, please contact Ciro Team’s privacy team at:

· Email: tanghaitian678@sina.com

We will strive to respond to your inquiry within 5 business days and work with you to address any issues or resolve your concerns.