Privacy Policy

RockAI (hereinafter referred to as "we") highly value the protection of users' ("you") personal information and privacy. We are well aware of the importance of personal information to you and will adopt corresponding security protection measures to safeguard your personal information in accordance with legal requirements and mature industry security standards. Through this Privacy Policy, we hope to clearly explain to you how we handle your personal information when you use our products/services, as well as the ways we provide for you to access, correct, delete, and protect this information.

This Privacy Policy will help you understand:

We will collect and use your information in accordance with the privacy policy and will not collect personal information in a bundled and compulsory manner merely because you consent to this privacy policy.

When you use or enable relevant functions or services, we will collect and use relevant information as necessary to implement the functions and services. Unless it is necessary information required to achieve basic business functions or as required by laws and regulations, you can refuse to provide it without affecting other functions or services. We will specify item by item in the privacy policy which information is necessary.

This Privacy Policy applies to the products and services provided to you by RockAI service providers through RockAI applications, web pages, mini-programs, RockAI software development kits (SDKs) and application programming interfaces (APIs) for third-party websites and applications, as well as innovative forms that emerge with the development of technology. If you use a certain service or several services provided by us or our affiliated companies and there is a separate privacy policy for it, the corresponding service or product shall be subject to the corresponding privacy policy; if there is no independent privacy policy, this policy shall also apply to this part of the products or services.

The following text will help you understand in detail how we collect, use, store, transmit, share, transfer (if applicable) and protect personal information; and help you understand the ways to query, access, delete, correct, and withdraw authorization of personal information. This policy is closely related to your use of our services. We recommend that you carefully read and understand the entire content of this policy and make an appropriate choice. The important terms regarding your personal information rights and interests have been highlighted in bold for your special attention.

【Special Notice】Before using the various products/services we provide, please carefully read and fully understand this "Privacy Policy" (the key content has been bolded for your special attention) and make a corresponding choice. Once you use or continue to use our products/services, it means that you consent to our handling of your relevant information in accordance with this privacy policy. If you are a minor under 18 years old, to ensure your safety when using or purchasing services through us, please make sure that you and your parents or guardians read and understand our privacy policy together to learn about and consent to how RockAI protects and uses the personal information of minors.

If you have any questions about this privacy policy, you can contact us through the methods provided in the "How to Contact Us" section of this privacy policy.

Please note that this policy does not apply to other third-party products/services that you access through our products/services ("other third parties", including your trading counterparts, any third-party websites, and third-party service providers, etc.). Other third parties may have their own privacy protection agreements. When you view web pages created by other third parties or use applications developed by other third parties, you may find cookies or pixel tags placed on such web pages or applications. These cookies or tags are not under our control, and their use is not restricted by this agreement. We will not assume any responsibility for your behavior and consequences of using personal information on third-party platforms.

This policy will help you understand the following:

I. How We Collect and Use Your Personal Information

II. How We Share, Transfer, and Publicly Disclose Your Personal Information

III. How We Store and Protect Your Personal Information

IV. How You Manage Your Personal Information

V. Protection of Minors' Personal Information

VI. Notices and Revisions

VII. How to Contact Us

VIII. Appendices

I. How We Collect and Use Your Personal Information

When you use our products/services, the scenarios where you need to or can choose to authorize us to collect and use personal information include:

1. To provide you with the basic functions of our products/services, you need to authorize us to collect and use necessary information. If you refuse to provide the aforementioned necessary information, you will not be able to use our products/services normally.

2. To provide you with the extended functions of our products/services, you can choose to authorize us to collect and use information. If you refuse to provide the aforementioned information, you will not be able to use the relevant additional functions normally or achieve the functional effects we intend to achieve, but it will not affect your normal use of the basic functions of our products/services.

(A) Scenarios Where You Need to Authorize Us to Collect and Use Personal Information

We will follow the principles of legitimacy, lawfulness, and necessity and collect and use your personal information for the following purposes stated in this policy.

1. Registration/Login

When you apply to use RockAI services, you can log in with your registered RockAI universal account. When registering a RockAI universal account, you need to provide us with your mobile phone number information.

We may send you the latest news about RockAI products and services through the mobile phone number you provided. If you do not wish to receive such news, you can refuse to receive such information according to the method provided in the news or contact us through the contact information in "How to Contact Us" for handling.

2. Large-model Application Experience

Our open platform provides a large-model application experience. To achieve this function, we will automatically receive and record the information you voluntarily enter during the interaction with RockAI and use this information to output content to you. Please refer to the "User Agreement", "Privacy Policy" and "Large-model Service Agreement" of the open platform for details.

(B) Scenarios Where You Can Choose to Authorize Us to Collect and Use Personal Information

You can choose to use the extended functions we provide. We will collect and use the following information in accordance with laws and regulations and based on your specific authorization. This type of information will be collected in the specific functions and business scenarios you choose. If you do not provide this information, it will not affect your use of the basic functions of RockAI.

1. Provide You with Security Protection

To ensure the security of your account, transaction, and system operation, and meet the relevant requirements of laws, regulations, and our agreement rules, during your use of our products/services, with your authorization, we will obtain your device information, account name, mobile phone number, conversation content, and feedback content to determine whether your current account login is abnormal.

To improve the security of the services we provide to you and more accurately prevent phishing website fraud and Trojan viruses, we may use or integrate your personal information, as well as the information that our affiliated companies and partners obtain with your authorization or legally share. Based on your usage habits and commonly used software information, etc., we will comprehensively judge the risks of your account and transactions, including verifying your identity, preventing, detecting, and investigating potential security risks such as fraud, network viruses, and cyber-attacks, as well as behaviors that violate our or our affiliated companies' agreements, policies, or rules, to protect the legitimate rights and interests of you, other users, us, or our affiliated companies, and record some links ("URLs") that we consider risky.

2. Content Evaluation Function

During the conversation, you can also evaluate the content output by RockAI, including likes, dislikes, etc. To continuously improve the quality of the content output by RockAI, we need to obtain your evaluation information, including the error-reporting reasons you actively submit. You can refuse to evaluate without affecting your enjoyment of the basic functions of RockAI.

3. Customer Service

When you report a problem, we may need you to provide and use your mobile phone number, email, QQ, RockAI account information. To ensure the security of your account, when providing customer service, we will use your mobile phone number, email, QQ, RockAI account information to verify your identity. When you need us to provide customer service related to the information during your use process, we will query your usage information. If you refuse to provide it, you will not be able to use the customer service function. We will also collect and use other information you voluntarily provide during the use of the customer service function to respond to your service requests.

4. Use of Cookies and Similar Technologies

(1) Use of Cookies

To ensure the normal and efficient operation of the application and provide you with an easier access experience, we will store a small data file named Cookie on your device terminal/system. Cookies will help you call up your information when you visit our website subsequently, simplify the process of filling in information, help you optimize the selection and interaction with advertisements, protect the security of your data, and optimize product function services, etc. We will not use Cookies for any purposes other than those described in this privacy policy. You can manage or delete Cookies according to your needs. You can clear all Cookies saved on your computer or mobile device. You have the right to accept or refuse Cookies. Most browsers will automatically accept Cookies, but you can usually modify the browser settings to refuse Cookies according to your needs; in addition, you can also clear all Cookies saved in the software.

(C) Exceptions to Obtaining Consent

Please be informed that in the following circumstances, we do not need to obtain your authorization and consent to collect and use personal information:

1. It is necessary to perform statutory duties or obligations.

2. It is necessary to respond to public health emergencies or to protect the life, health, and property safety of natural persons in emergency situations.

3. For the public interest, in the course of news reporting, public opinion supervision, etc., and processing personal information within a reasonable scope.

4. Processing personal information that has been publicly disclosed by individuals themselves or other legally publicly disclosed personal information within a reasonable scope as stipulated in the "Personal Information Protection Law of the People's Republic of China".

5. Other circumstances stipulated by laws and administrative regulations.

Please note that anonymized information and other information that cannot identify the identity of a specific natural person or reflect the activities of a specific natural person do not belong to personal information. If we combine information that cannot be linked to any specific individual with other information to identify the identity of a natural person, or use it in combination with personal information, then during the period of combined use, such information will be regarded as personal information.

(D) Rules for the Use of Personal Information

To meet your needs and maintain and improve the quality of our products or services, we will use the following information in accordance with laws and regulations and based on your specific authorization:

1. We may collect the information you actively provide to us when participating in product/service surveys, as well as the relevant information you provide during interactions with our affiliated companies and partners, to help you track order status, initiate user complaints, and for us to optimize the quality and process of customer service. When we provide your personal information to third parties to achieve the above-mentioned purposes, we will inform you again and seek your separate consent.

2. We may use the personal information collected in our business for statistical analysis and operational improvement, and use the de-identified information that cannot identify your identity and cannot be restored to establish a database and carry out commercial utilization. For example, through statistical analysis of your location, usage behavior, etc., we can improve our products, services, or marketing plans; another example is for technical upgrades, network maintenance, troubleshooting, internal policy and process formulation, and generation of internal reports to improve our systems.

When we want to use information for other purposes not stated in this agreement, we will, in accordance with the requirements of laws, regulations, and national standards, seek your consent again in an appropriate manner.

II. How We Share, Transfer, and Publicly Disclose Your Personal Information

(A) Partners Involved in the Process of Data Use

1. Basic Principles

We attach great importance to the protection of your personal information. Without your explicit consent, we will not share your personal information with third-party companies, organizations, and individuals other than us, unless it is anonymized or de-identified information that cannot be identified or associated with you, and the sharing third-party cannot re-identify the natural person subject of such information.

We will only share your personal information for legitimate, justifiable, necessary, specific, and clear purposes, and only share the necessary personal information. If we share your personal sensitive information, we will seek your authorization and consent again. If a third-party changes or exceeds the scope of your original authorization and consent to use your personal information, we will require the third-party to seek your authorization and consent again.

At the same time, we will conduct a personal information security impact assessment in advance for the sharing and transfer of personal information, and adopt effective technical protection measures for the output form, circulation, use, etc. At the cooperation agreement level, we will strictly require partners' information protection obligations and responsibilities and sign a data security protection agreement with business partners before cooperation.

2. Entrusted Processing

We may entrust authorized partners to process your personal information so that the authorized partners can provide certain services or perform functions on our behalf. We will only entrust them to process your information for the legitimate, justifiable, necessary, specific, and clear purposes stated in this policy. The authorized partners can only access the information required for their duties, and we will require through the agreement that they shall not use this information for any purpose beyond the scope of the entrustment. If the authorized partner uses your information for a purpose not entrusted by us, it will obtain your separate consent.

3. Joint Processing

For scenarios of joint processing of personal information, we will sign relevant agreements with partners in accordance with laws and regulations and stipulate the respective rights and obligations to ensure compliance with relevant laws and regulations and data security during the use of relevant personal information.

4. Scope of Partners

If specific functions and scenarios involve services provided by our affiliated companies or third-parties, the scope of partners includes our affiliated companies and third-parties.

(B) Transfer

1. We will not transfer your personal information to any other third-party unless we obtain your explicit consent.

2. With the development of our business, our affiliated companies and we may engage in mergers, acquisitions, asset transfers, or similar transactions. If the transfer of personal information is involved, we will require the company or organization that acquires your personal information to continue to be bound by this privacy policy. Otherwise, we will require the company or organization to seek your authorization and consent again.

(C) Public Disclosure

We will only publicly disclose your personal information in the following circumstances and under the premise of adopting security protection measures in line with industry standards:

1. According to your needs, disclose the personal information you specify in the disclosure method with your explicit and separate consent.

2. When it is necessary to provide your personal information as required by laws, regulations, mandatory administrative law enforcement, or judicial requirements, we may publicly disclose your personal information according to the type of personal information required and the disclosure method. Under the premise of compliance with laws and regulations, when we receive a request for the above-mentioned information disclosure, we will require the presentation of corresponding legal documents, such as subpoenas or investigation letters.

3. If you violate laws, regulations, or RockAI-related agreements and rules, or to protect the personal and property safety of RockAI or the public from infringement, we may disclose your account information in accordance with laws, regulations, platform agreements, or with your consent.

(D) Exceptions to Obtaining Authorization and Consent in Advance for Sharing, Transferring, and Publicly Disclosing Personal Information

In the following circumstances, sharing, transferring, and publicly disclosing your personal information do not require prior authorization and consent from you:

1. It is necessary to perform statutory duties or obligations.

2. It is necessary to respond to public health emergencies or to protect the life, health, and property safety of natural persons in emergency situations.

3. For the public interest, in the course of news reporting, public opinion supervision, etc., and processing personal information within a reasonable scope.

4. Processing personal information that has been publicly disclosed by individuals themselves or other legally publicly disclosed personal information within a reasonable scope as stipulated in the "Personal Information Protection Law of the People's Republic of China".

5. Other circumstances stipulated by laws and administrative regulations.

In addition, according to the law, for the sharing, transfer, and public disclosure of de-identified personal information, and ensuring that the data recipient cannot restore and re-identify the personal information subject, our handling of such data will not require separate notice to you and obtaining your consent.

III. How We Store and Protect Your Personal Information

(A) Storage of Personal Information

1. Retention Period: Unless as required by laws, regulations or mutual agreement, we will only retain your relevant personal information for the shortest period necessary to achieve the purpose. When you actively cancel your account or request us to delete your personal information, we will delete your personal information or anonymize it as soon as possible in accordance with the requirements of laws and regulations. For the relevant rules and procedures regarding account cancellation, please refer to the deion of "Account Cancellation" in Section V (C) of this policy.

2. Storage Location: The personal information we collect and generate within the People's Republic of China will be stored within China.

Please be aware that we will only transfer your personal information outside of China when the following conditions are met simultaneously:

(1) Due to business needs, it is indeed necessary to provide personal information outside the People's Republic of China, and it has passed the security assessment organized by the national cyberspace administration in accordance with laws and regulations, or has been certified for personal information protection by a professional institution, or has entered into a contract with the overseas recipient to stipulate the rights and obligations of both parties, or meets other conditions stipulated by laws, administrative regulations or the national cyberspace administration.

(2) We will inform you of the name or title, contact information, processing purpose, processing method, types of personal information of the overseas recipient, as well as the way and procedure for you to exercise the rights stipulated in this law against the overseas recipient, and obtain your separate consent.

In the above-mentioned situations, we will require the data recipient to handle personal information in accordance with this privacy policy and other relevant security and confidentiality measures to meet the personal information protection standards stipulated in the "Personal Information Protection Law of the People's Republic of China".

3. Termination of Operation: In the event of termination of operation, etc., we will notify you at least 30 days in advance and delete or anonymize your personal information after the termination of operation.

(B) Protection Measures for Personal Information

1. Data Security Measures

To ensure the security of your information, we strive to adopt various physical, electronic and management security measures in line with industry standards to protect your personal information. We establish a data classification and grading system, data security management norms and data security development norms to manage and standardize the storage and use of personal information. RockAI conducts comprehensive security control of data through information contactor confidentiality agreements, monitoring and audit mechanisms. This is to prevent your personal information from being accessed without authorization, publicly disclosed, used, modified, damaged or lost. For example, when exchanging data (such as credit card information) between your browser and the "service", we adopt SSL encryption protection technology; at the same time, we provide https secure browsing for the website itself; use encryption technology to ensure data confidentiality; use trusted protection mechanisms to prevent data from being maliciously attacked; deploy access control mechanisms to ensure that only authorized personnel can access personal information; and hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

2. We will use encryption technology, anonymization processing and other relevant reasonable and feasible means that are no less than those of industry peers to protect your personal information, and use security protection mechanisms to prevent your personal information from being maliciously attacked.

3. We will establish a dedicated security department, security management system and data security process to ensure the security of your personal information. We adopt strict data use and access systems to ensure that only authorized personnel can access your personal information, and conduct security audits on data and technology in a timely manner.

4. Although the above-mentioned reasonable and effective measures have been taken and the standards required by relevant laws and regulations have been complied with, please understand that due to technical limitations and various possible malicious means, in the Internet industry, even if we do our best to strengthen security measures, it is impossible to always ensure 100% security of information. We will do our best to ensure the security of the personal information you provide to us.

5. Please be aware and understand that the Internet is not an absolutely secure environment. We strongly recommend that you assist us in ensuring the security of your account by using secure methods and complex passwords. If you find that your personal information has been leaked, especially if your account or password has been leaked, please contact us immediately through the contact information provided in this privacy policy so that we can take corresponding measures.

6. Once you leave "RockAI" and related services and browse or use other websites, services and content resources, we will not have the ability and direct obligation to protect any personal information you submit on software or websites outside of RockAI and related services, regardless of whether you log in, browse or use the above-mentioned software or websites based on the links or guidance of "RockAI".

IV. How You Manage Your Personal Information

You have the following rights regarding your personal information:

(A) Access, Correction, Deletion of Your Personal Information

You have the right to access and correct your personal information, except in cases where otherwise provided by laws and regulations.

(B) Deletion of Your Personal Information

You have the right to delete the personal information we have collected about you.

(C) Account Cancellation

You have the right to cancel your RockAI account. You can perform the online operation by accessing "Web Version"-"Account Cancellation" on our page. After your successful cancellation, we will delete your personal information or anonymize it as soon as possible in accordance with the requirements of laws and regulations.

If you need to access, correct or delete your personal information, cancel your account, or if you think RockAI has collected or used your personal information in violation of laws, you can contact us through our customer service or other means provided in this privacy policy. To ensure security, we may need you to provide corresponding means to prove your identity and the legitimacy of your request. We will reply to your request within 15 days after receiving your feedback and verifying your identity. In principle, we do not charge for your reasonable requests, but for requests that are repeated multiple times and exceed a reasonable limit, we will charge certain cost fees as appropriate. We may reject requests that are unsubstantiated and repeated, require excessive technical means (for example, the need to develop a new system or fundamentally change current practices), pose risks to the legitimate rights and interests of others, or are extremely unrealistic (for example, information stored on backup tapes).

(D) Complaint and Report

You can file a complaint or report in accordance with the system we have publicly announced. If you think your personal information rights may be violated, or find clues of violations of personal information rights (for example, believing that our collection of your personal information violates legal provisions or mutual agreements), you can contact us through "How to Contact Us" in this privacy agreement. We will verify and promptly feedback on your complaints and reports.

(E) Access to the Privacy Policy

1. You can view the entire content of this privacy policy on the registration and product usage pages.

2. Please note that the "RockAI" and related services described in this privacy policy may vary depending on factors such as the mobile phone model, system version, software application version, and mobile client you use. The final products and services are subject to the "RockAI" software and related services you use.

(F) Notice of Termination of Operation

RockAI is willing to accompany you all the time. If we stop operating, we will promptly stop collecting your personal information, notify you of the termination of operation in the form of individual delivery or announcement, and delete or anonymize the personal information we hold about you.

V. Protection of Minors' Personal Information

RockAI attaches great importance to the protection of minors' personal information. Our website and services are mainly targeted at adults. If you are a minor, it is recommended that your parents or guardians carefully read this privacy policy, and you can use our services or provide us with information only with the consent of your parents or guardians.

For the collection of minors' personal information when using our products or services with the consent of their parents or guardians, we will only use, share, transfer or disclose this information when permitted by laws and regulations, with the explicit consent of parents or guardians, or when it is necessary to protect minors.

If we find that we have collected minors' personal information without prior verifiable consent from parents or legal guardians, we will try to delete the relevant data as soon as possible.

VI. Notices and Revisions
To provide you with better services, our business will change from time to time, and this privacy policy will also be adjusted accordingly. Without your explicit consent, we will not reduce the rights you should enjoy under this privacy policy. We will issue updated versions on our website and mobile terminal or remind you of relevant content updates in other ways. You are also welcome to visit us to keep informed of the latest privacy policy in a timely manner. After adjusting the privacy policy, we will seek your consent again through pop-up windows, notifications, etc.

VII. How to Contact Us

You can contact us through the following methods, and we will reply to your request within 15 days:

1. You can contact us through the customer service QR code and online feedback system in the RockAI interface.

2. We have also set up a dedicated personal information protection team. You can contact us via contact@rockai.net or fawu@stonehill-tech.com, or send a letter to the following address:

Company Full Name: Shanghai RockAI Artificial Intelligence Technology Co., Ltd.

Registered Address: 3rd Floor, 665 Zhangjiang Road, China (Shanghai) Pilot Free Trade Zone

Contact Address: 1455 Huanke Road, Pudong New Area, Shanghai

VIII. Appendices:

1. Personal Information: It refers to various types of information recorded electronically or in other ways that can identify the identity of a specific natural person alone or in combination with other information, or reflect the activities of a specific natural person. The personal information that may be involved in this privacy policy includes but is not limited to: basic personal information (including name, phone number, gender, address, birthday, etc.); personal identity information (including ID card, military officer's certificate, passport, driver's license, etc.); network identity identification information (including system account, IP address, email address, and passwords, passwords, password protection answers related to the above); personal property information (including bank account, transaction and consumption records, credit records, and virtual property information, etc.); personal health and physiological information (including symptoms, medical records, medical history, etc.); contact information (including address book information, friend list, etc.); personal Internet browsing records (including website browsing records, click records, etc.); personal device information (including device model, operating system version, device settings, unique device identifier (IMEI/AndroidID/IDFA/OPENUDID/GUID/SIM card IMSI information), mobile application list, phone status, device environment and other software and hardware characteristic information), device location-related information (including your authorized GPS location and sensor information such as WLAN access points, Bluetooth and base stations) (including unique device identification codes and other information describing the basic situation of personal common devices); personal location information (including travel trajectory, precise positioning information, accommodation information, etc.).

The following information does not belong to personal information: anonymized information, that is, information that cannot identify the personal information subject through technical processing of personal information and cannot be restored after being anonymized does not belong to personal information; other information that cannot identify the identity of a specific natural person or reflect the activities of a specific natural person does not belong to personal information.

2. Personal Sensitive Information: It refers to personal information that, once leaked, illegally provided or misused, may endanger personal and property safety, and is extremely likely to cause damage to personal reputation, physical and mental health, or discriminatory treatment. It includes ID cards and other identification documents, facial recognition features, driver's licenses, location information, travel information, bank accounts, communication records and content, payment information, cash-withdrawal records, travel trajectories, transaction information, personal information of children under 14 years old (including 14 years old), recording information, video information, mobile phone numbers, email addresses.

3. Affiliated Companies: It refers to the affiliated companies disclosed in the latest annual report of Stonehill (stock code: 002195).