Last Updated: August 29, 2025
Effective Date: August 29, 2025
The WitCEO App is developed by Changsha Houlang Network Technology Co., Ltd. (registered address: Room 807, Building F1, Luguyuyuan, No. 27 Wenxuan Road, High-tech Development Zone, Changsha City, Hunan Province) (hereinafter collectively referred to as "we"). We provide products and services (hereinafter collectively referred to as "WitCEO Products and Services") through the WitCEO App.
We respect and protect users' privacy and data. When you use WitCEO Products and Services, we will collect, use, store, and share your personal information and other non-identifiable relevant data. We are well aware of the importance of personal information to you and will make every effort to protect the security and reliability of your personal information.
We hope to inform you through this "WitCEO Privacy Policy" (hereinafter referred to as "this Policy") about how we collect, use, store, and share such data when you use WitCEO Products and Services, as well as the methods we provide for you to access, correct, delete, and protect your personal information.
We hereby remind you:
1. This Policy applies only to WitCEO Products and Services and does not apply to products or services provided to you by third parties through WitCEO Products and Services. When you link to other websites, clients, or mobile applications through WitCEO Products and Services, we cannot control the collection or acquisition of your information by such third parties.
2. WitCEO Products and Services are only available to adults aged 18 and above. We require registered users to be natural persons with full capacity for civil conduct, and minors are not allowed to register their own user accounts. We further declare that WitCEO Products and Services are not available to any children under the age of 14.
3. This Policy is closely related to the WitCEO Products and Services you use. For clauses in this Policy that may have a significant relationship with your rights and interests, we have marked them in bold. Before using WitCEO Products and Services, you must carefully read and confirm that you have fully understood the content stated in this Policy. Please pay special attention to the clauses marked in bold, but also note the importance of the entire content of this Policy. You should fully understand, confirm, and agree to all the content of this Policy before starting to use WitCEO Products and Services, so that you can make appropriate choices according to the guidelines of this Policy.
This Policy helps you understand the following contents:
1. How we collect and use your personal information
2. How we store your personal information
3. How we use Cookies and related technologies
4. How we share, transfer, and publicly disclose your personal information
5. How we protect your personal information
6. How you can manage your personal information
7. Revision and update of this Policy
8. How to contact us
9. Relevant terms
We hereby declare and promise:
1. In this Privacy Policy, we will clearly inform you of the purposes, methods, and scopes of collecting and using personal information by this App and the third-party SDKs we use. For detailed information, please refer to the "List of Third-Party Information Sharing".
2. Before you first launch this App and explicitly authorize and agree to this Privacy Policy, this App and the connected third-party SDKs will not collect or use any of your personal information in advance, including but not limited to device identifiers (such as IMEI, OAID, IMSI, MAC address), application lists, and other information.
In the process of you using WitCEO Products and Services, in order to realize the functions of the products and services, we only collect the following information related to you in accordance with the principles of legality, legitimacy, and necessity.
1. User Registration: To help you successfully register and log in to your WitCEO account and further provide you with WitCEO Products and Services, you need to provide us with your mobile phone number and SMS verification code.
2. Use of Services: To make it easier for you to use the services, we may collect information about the device you use to access our products and/or services (including device name, device model, device identifiers (such as OAID), operating system and application version, language settings, screen resolution, service provider network ID (PLMN)) to provide you with the best way to display product information. We may also use your personal information as described above to continuously improve and optimize the above-mentioned functions.
3. Purchase of Services: When you purchase the services you need and apply for an invoice for them, we will collect your order number, order placement time, payment amount, and payment method information for the purpose of sales statistics and providing you with after-sales support. All the above information constitutes your "order information". We will use this information to verify your identity, confirm transactions and payments, check your orders, and provide customer service and after-sales service; we will also use your order information to determine whether there are abnormalities in your transactions to protect the security of your transactions.
4. Payment Function: After you place an order, you can choose the payment services provided by WeChat Pay, Alipay, or Apple Store. The payment function itself does not collect your personal information, but we need to share your order number and transaction amount information with these payment institutions so that they can confirm your payment instructions and complete the payment.
5. Improvement of Service Quality: To enhance your service experience, improve service quality, or provide you with better or more appropriate services, we may also obtain other information about you that we reasonably need to provide services and improve service quality, including the information you provide when contacting customer service, the information you send to us in response to surveys you participate in, and the information we obtain when you interact with our affiliated companies and partners. For the information collected from your various devices, we may associate it so that we can provide you with consistent services on these devices. We may combine information from one service with information from other services to provide you with better services and content.
To enhance your experience of using our services, we may collect and use your personal information in the following additional functions. If you do not provide this personal information, you can still use the basic functions of this App. Please note that by enabling these permissions, you are authorizing us to collect and use this personal information to realize the above-mentioned functions, and by disabling these permissions, you are revoking these authorizations. We will not continue to collect and use your personal information, nor can we provide you with the above-mentioned functions corresponding to these authorizations. Your decision to turn off permissions will not affect the previous processing of personal information based on your authorization for the following contents:
1. Additional Functions Based on Camera: We require you to authorize the camera function on your device so that you can use the camera to take photos for custom avatars or upload images on other image file pages.
2. Additional Functions Based on Image Upload: We need you to authorize WitCEO to access your photo album to help you take photos with your mobile phone, upload photos, and easily change your avatar, etc.
To improve the system security when you use our products and/or services, more accurately prevent phishing website fraud, and protect account security, we may judge your account risk by understanding your browsing information, order information, information about the software you frequently use, device information, and other means, and may record some links (URLs) that we consider risky; we will also collect your device information to analyze problems occurring in the WitCEO system, count traffic, rank possible risks, and rank the abnormal information you choose to send to us.
You fully understand and agree that, within the scope permitted by law, we may collect and use your personal information without your authorization and consent in any of the following circumstances:
1. Related to our performance of obligations stipulated in applicable laws and regulations;
2. Directly related to national security and national defense security;
3. Directly related to public security, public health, and major public interests;
4. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
5. For the purpose of protecting the life, health, property, and other major legitimate rights and interests of you or other individuals, but it is difficult to obtain the authorization and consent of the person concerned;
6. The personal information involved is publicly disclosed by you to the public;
7. Necessary for signing and performing the contract according to your requirements;
8. Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure, and other channels;
9. Conducting news reporting, public opinion supervision, and other activities for the public interest, and processing personal information within a reasonable scope;
10. Necessary for maintaining the safe and stable operation of the provided products and services, such as detecting and handling content and service failures.
1. We will use the collected personal information in accordance with the agreement of this Privacy Policy and realize the functions of our products and/or services.
2. After collecting your personal information, we will process the data confidentially through technical means, and the processed information will not be able to identify the subject. Please understand and agree that in this case, we have the right to use the processed information; and without disclosing your personal information, we have the right to analyze and commercially use the user database.
3. Please note that all personal information you provide when using our products and/or services will be continuously authorized to us during your use of our products and/or services, unless you delete it. When you cancel your account, we will stop using and delete your personal information within a reasonable period.
4. We may compile statistical data on the use of our products and/or services and may share such statistical data with the public or third parties to show the overall use trend of our products and/or services. However, such statistical data does not contain any identifying information about you.
5. When we intend to use your personal information for purposes other than those stated in this Policy, or when the information collected for a specific purpose is used for other purposes, we will seek your prior consent in the form of a checkbox initiated by you.
1. In principle, the personal information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. We will ensure the storage security of personal information in a manner permitted by law.
2. We will only retain your personal information for the shortest retention period required by the purposes stated in this Policy and the provisions of laws and regulations. After the expiration of the aforementioned period, we will delete your personal information or anonymize it. In addition, if we terminate the provision of services, we will delete or anonymize your personal information after terminating the provision of services, except in cases where laws and regulations, relevant national standards have other requirements or we need to retain your personal information to fulfill our compliance obligations.
3. When you successfully apply for account cancellation, we will delete or anonymize your personal information.
1. We and our third-party partners will use Cookies, log files, web beacons, scripts, tags, and other tracking technologies (collectively referred to as "Cookies and Related Technologies") on your computer or mobile device. We and our third-party partners may collect your information through Cookies to remember your identity and analyze how you use our services.
2. The collection and use of your information by third-party partners through Cookies is not subject to this Policy, but to their own information protection statements. We are not responsible for the Cookies or similar technologies of third parties.
3. If your browser or browser add-on services allow, you can modify your acceptance level of Cookies or refuse our Cookies. However, if you do so, we may not be able to provide you with the best user experience of WitCEO Products and Services, and some functions may not work properly.
We will only share your personal information in the following circumstances:
1. Obtaining your explicit authorization or consent in advance;
2. Necessary for performing legal obligations: sharing your personal information in accordance with the requirements of applicable laws and regulations, litigation, dispute resolution, or the legally proposed requirements of administrative and judicial organs, and for the performance of other legal obligations;
3. Within the scope required or permitted by law, it is necessary to provide such information for the purpose of protecting the interests, property, or safety of users or the public from damage;
4. Some functions of WitCEO Products and Services are provided by our affiliated companies. To realize these functions, we may share your personal information with our affiliated companies within the minimum necessary scope;
5. Sharing with partners: Only for the purposes stated in this Policy, some of our services will be provided by partners. We may share some of your personal information with partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share the personal information necessary for providing services. Our partners have no right to use the shared personal information for any other purposes. To ensure the realization of some independent functions, some of our services and functions are provided by third-party SDKs. We will carefully evaluate the purpose of using such SDKs.
We will not transfer your personal information to any company, organization, or individual, except in the following cases:
1. We have obtained your explicit consent or authorization in advance;
2. Provision is necessary in accordance with the requirements of applicable laws and regulations, legal procedures, or mandatory administrative or judicial requirements;
3. In the event of mergers, acquisitions, asset transfers, bankruptcies, or similar transactions, your personal information may be transferred as part of such transactions. If personal information is involved in the transfer, we will inform you of the relevant situation through notifications, announcements, and other forms, and will continue to protect it in accordance with laws and regulations and standards not lower than those required by this Policy, or require the new transferee who holds your personal information to continue to be bound by this Policy; otherwise, we will require the transferee to seek authorization and consent from you again. In case of bankruptcy and no successor, your personal information will be deleted.
In principle, we will not publicly disclose your personal information. We will only publicly disclose your personal information when authorized by laws and regulations or when there is a reasonable reason to do so, and in accordance with the following requirements:
1. Conduct a personal information security impact assessment in advance and take effective protection measures based on the assessment results;
2. Inform you of the purpose, type of personal information to be publicly disclosed, and the content of the sensitive information involved, and obtain your explicit consent in advance.
Please note that in the following circumstances, we do not need to obtain your authorization and consent in advance when sharing, transferring, or publicly disclosing your personal information:
1. Related to our performance of obligations stipulated in laws and regulations;
2. Directly related to national security and national defense security;
3. Directly related to public security, public health, and major public interests;
4. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
5. For the purpose of protecting the life, health, property, and other major legitimate rights and interests of you or other individuals, but it is difficult to obtain the authorization and consent of the person concerned;
6. The personal information you have publicly disclosed to the public;
7. Collecting your personal information from legally publicly disclosed information, such as legal news reports, government information disclosure, and other channels.
1. We will take all reasonably feasible measures to protect your personal information and prevent data from being accessed, publicly disclosed, used, modified, damaged, or lost without authorization. For example, data exchanged between your browser and the "Service" is protected by SSL encryption; we also provide HTTPS secure browsing for the websites applicable to this Policy; we will use encryption technology to ensure data confidentiality; we will use trusted protection mechanisms to prevent data from malicious attacks.
2. We will establish a special management system and deploy access control mechanisms to ensure that only authorized personnel can access personal information; in addition, we will also conduct security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.
3. We strictly comply with the requirements of the Cybersecurity Law of the People's Republic of China, the Personal Information Protection Law of the People's Republic of China, and other applicable laws and regulations, and proactively follow the guidelines of the Information Security Technology - Personal Information Security Specification (GB/T 35273 - 2020).
4. The Internet is not an absolutely secure environment, but we will do our best to ensure the security of any information you send to us. In the event of a personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation of the security incident and its possible impact, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly inform you of the relevant situation of the incident through email, letter, phone call, pop-up notification, and other methods. If it is difficult to inform each individual information subject one by one, we will issue an announcement in a reasonable and effective manner. At the same time, we will also proactively report the disposal of the personal information security incident in accordance with the requirements of the regulatory authorities.
You have the right to access your personal information at any time. However, for account security purposes, we may limit the number of login verification codes you can receive each day.
When using the WitCEO App:
1. You can access your username and avatar through the "Me" interface;
2. You can access your audio recording files through the "Home" interface;
3. You can access and manage your WitCEO devices through "Me - My WitCEO Devices".
If you are unable to access your personal information in the WitCEO App through the above methods, you may send an email to WitCEO@163.com to submit an access request. We will respond to your access request within 15 days.
You have the right to correct your personal information at any time.
When using the WitCEO App:
1. You may send an email to WitCEO@163.com to apply to us for correcting other personal information. We will respond to your correction request within 15 days.
You have the right to delete your personal information at any time.
When using the WitCEO App:
1. You can delete your audio recording files through the "Recordings" interface;
2. You may send an email to WitCEO@163.com to apply to us for deleting your personal information. We will process your request within 15 days.
After you delete your personal information, due to legal and regulatory requirements as well as security technology needs, we may not immediately delete the corresponding backup information. We will securely store your personal information without further using it until the backup is updated to delete such information or anonymize it.
1. Please understand that certain basic personal information is required for each business function to be fulfilled. Regarding the collection and use of personal information beyond the minimum set, you may grant or withdraw your authorized consent at any time.
2. To withdraw consent for WitCEO products and services, you may send an email to WitCEO@163.com to submit a consent withdrawal application. We will process your request within 15 days.
3. You may also withdraw all authorizations for us to continue collecting your personal information by canceling your account.
4. After you withdraw your authorization or consent, we will no longer process the corresponding personal information. However, the withdrawal of your authorization or consent will not affect the personal information processing activities we have already conducted based on your previous authorization.
1. You may cancel your account at any time. You can cancel your account through "Me - Settings - Cancel Account", or send an email to WitCEO@163.com to apply to us for account cancellation. We will process your request within 15 days.
2. After account cancellation, we will stop providing WitCEO products and services to you, and delete or anonymize your personal information in accordance with your request. However, if the retention period specified by laws and regulations has not expired, or if it is technically difficult to delete the personal information, we will stop processing the information except for storing it and taking necessary security protection measures.
1. You have the right to obtain a copy of your personal information. You may send an email to WitCEO@163.com to apply to us for obtaining a copy of your personal information. We will process your request within 15 days.
2. When technically feasible (e.g., when data interfaces are compatible), we will also transmit the copy of your personal information directly to the third party you designate, as requested by you.
1. If you believe that we have violated any laws, regulations, or the provisions of this Policy, you may contact us through the contact information listed in Article VIII of this Policy.
2. To ensure the security of your information, we may require you to provide a written request or verify your identity through other means. We will respond to your request within 15 days after receiving your feedback and verifying your identity.
3. In principle, we will not charge fees for your reasonable requests. However, for repeated requests that exceed a reasonable limit, we may charge a certain cost fee depending on the circumstances. We may refuse requests that are unnecessarily repetitive, require excessive technical measures (e.g., developing a new system or fundamentally changing existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical (e.g., involving information stored on backup tapes).
4. Under the following circumstances, in accordance with the requirements of laws and regulations, we will be unable to respond to your request:
(1) Requests related to our performance of obligations stipulated by laws and regulations;
(2) Requests directly related to national security and national defense security;
(3) Requests directly related to public security, public health, and major public interests;
(4) Requests directly related to criminal investigation, prosecution, trial, and execution of judgments;
(5) Where we have sufficient evidence to prove that you have subjective malice or abuse your rights;
(6) Circumstances where it is necessary to protect your major legitimate rights and interests or those of other individuals (such as life and property) but it is difficult to obtain your authorized consent;
(7) Responding to your request will cause serious harm to the legitimate rights and interests of you, other individuals, or organizations;
(8) Requests involving trade secrets.
1. We may revise this Policy from time to time, and such revisions shall form part of this Policy. Without your explicit consent, we will not substantially reduce the rights you are entitled to under this Policy.
2. We will publish any changes made to this Policy in a prominent position within the WitCEO products.
1. If you have any questions, comments, or suggestions regarding this Policy, or wish to discuss this Policy or any privacy - related matters with us, please contact us via WitCEO@163.com. Generally, we will reply within 15 days.
2. If you believe that our personal information processing activities have infringed upon your legitimate rights and interests, you may also file a complaint or report with regulatory authorities such as the cyberspace administration, the industry and information technology department, the public security department, and the market supervision department.
1. "Personal Information" refers to various types of information, recorded in electronic or other forms, that relate to an identified or identifiable natural person, excluding information that has been anonymized.
2. "Relevant Data" refers to data collected through WitCEO products and services other than personal information.
3. "Partners" refer to third - party service providers that assist Changsha Houlang in providing WitCEO products and services.
4. "De - identification" refers to the process of processing personal information such that the specific natural person cannot be identified without the assistance of additional information.
5. "Anonymization" refers to the process of processing personal information such that the specific natural person cannot be identified and the information cannot be restored.
Changsha Houlang Network Technology Co., Ltd.
August 29, 2025