Privacy Policy

(I) Principles for our collection and use of personal information

We will collect and use your personal information in a lawful, legitimate, and necessary manner, in accordance with laws and regulations and business needs, and will not collect information unrelated to our business or collect information by improper means.

(II) Purposes for our collection and use of personal information

To comply with Chinese laws and regulations, to provide services to you, to protect the security of your account and system operation, and to improve user experience, we will collect relevant information generated in the course of your use of our services, including:

[Wan Tou Chang Hong Mini Program] Information processed by the developer

In the Wan Tou Chang Hong mini program, we only process information necessary to provide mini program features, and we collect and use such information only after obtaining your explicit authorization and consent:

(1) Mobile phone number: used for account login verification, password recovery, business notifications, and identity verification.

(2) WeChat nickname and profile photo: used for display in the mini program personal center, to distinguish platform users, and to improve basic account profile display.

(3) WeChat OpenID (WeChat unique identifier): when you use the "Bind WeChat ID" feature, after you actively tap "Confirm Binding" and give explicit consent, we obtain and store it through WeChat platform interfaces to associate your WeChat ID with your Wan Tou Chang Hong account for WeChat Pay, payment order association, and account security verification; it will not be used for purposes other than those stated here.

1. Registration and login

1.1 Registering and logging in to an account

1.1.1 You may log in to Wan Tou Chang Hong products or services using your mobile phone number (we will use SMS verification codes in this process) or account credentials (user ID and password). Your account will be automatically registered upon first login. You may also choose to provide nickname, profile photo, email, gender, date of birth, region, personal introduction, and binding a third-party account to complete your profile as needed.

1.1.2 You may also log in to and use Wan Tou Chang Hong using a third-party account (which requires calling a third-party SDK) and may need network permission and related network information. You must also authorize us to obtain your public information registered on the third-party platform (profile photo, nickname, and region) to bind with your Wan Tou Chang Hong account so that you can log in and use this product and related services directly.

1.1.3 Based on our cooperation with telecommunications operators, when you use the "one-tap login" feature, we will, with your authorization, call the third-party operator (China Telecom / China Unicom / China Mobile) SDK to complete necessary device security verification, account registration, and login for quick login. We may need to request network permission, read phone state, and read/write external storage permission, involving mobile phone number, operation logs, network IP address, network type, registered mobile number, local number, hardware vendor, application process information, network connection type, network status information, network address, operator type, handset device type, handset device vendor, handset OS type and version, and other device information.

1.1.4 When you use account services such as password recovery/modification, unbinding, or account cancellation, we need to verify relevant personal information, mainly including: identity information (name, mobile number), device information (operating system, handset model), security status, account information (user ID, nickname, password, years since registration, bound third-party account), and value-added service purchase records, for account security purposes.

1.1.5 When you use fingerprint or facial recognition to unlock or log in, we will request fingerprint / Face ID permission. If you refuse to provide it, you will not be able to use the related services, but other features and services will not be affected.

1.1.6 When you use the Wan Tou Chang Hong mini program "Bind WeChat ID" feature, the purpose of collection is to associate your own WeChat ID with your Wan Tou Chang Hong account so that you can use WeChat Pay-related features, establish the relationship between payment orders and your account, and perform payment and security verification to prevent account impersonation. Method of collection: only after you actively enter the binding page, read the binding instructions, and tap "Confirm Binding" will we call WeChat login capabilities (such as wx.login) to obtain a temporary credential, which our server exchanges with the WeChat platform for your WeChat OpenID and, where necessary, WeChat UnionID; we do not collect the foregoing by default or without your confirmation. Use: the above identifiers are used only for binding your account to your WeChat identity, WeChat Pay pre-order placement and order verification, account security verification, and related services described in this Policy; without your separate explicit consent, they will not be used for marketing or other unrelated purposes. You should bind only the WeChat account you personally use and must not bind someone else's WeChat account.

2. Display, playback, and browsing

2.1 After entering the home page, basic services (browsing news and market data) require network permission. To ensure service security and stability, after you agree to this Privacy Policy we collect device identifiers (including OAID and Android ID), device model, operating system version, IP address, and network type for network communication, fault diagnosis, and experience optimization. After you stop using Wan Tou Chang Hong, information collected in guest browsing mode will be deleted or anonymized after one month. If we need to remind you of important news on the lock screen or desktop, we will separately request lock-screen display and background pop-up interface permissions.

3. Publishing and interactive communication

3.1 This app provides publishing and interactive services for news, market data, and related content. In accordance with the Cybersecurity Law of the People's Republic of China, the Provisions on the Administration of Internet News Information Services, the Provisions on the Administration of Information Services of Mobile Internet Applications, and app security assessment filing requirements, and for service push and operations, we need real-name authentication and retention of log records for regulatory traceability. The personal information involved is as follows.

Real-name authentication information (see Section 1.2 of this Policy) and log records are involved. Log records include terminal IP address, terminal model, network source address, destination address, network source port, client hardware characteristics, user account information, operation time, operation type, and browsing and published content (browsing, likes, follow/unfollow, comments, replies, private messages, reposts or forwards, shares, favorites, searches, Q&A, and published text/images/audio/video). You may refuse to provide the above information without affecting your use of other features.

3.1.1 When you like, follow/unfollow, comment, reply, send private messages, repost or forward, share, favorite, search, ask/answer questions, or publish text/images/audio/video in stock discussion communities, circles, topics, news, or content platforms, we will display your nickname, profile photo, published content (including likes, comments, forwards, and shares), publish time, publish type, operating device and system (PC, mobile, Android, iOS), years since registration, and follow list.

3.2 When you upload/edit/share/download/recognize images and audio/video, live stream, or change your profile photo, we will request your authorization for camera, photo album and device storage, and microphone permissions. If you refuse authorization, you will not be able to use the related features, but other features will not be affected.

3.3 Sharing: When you use WeChat/Weibo/QQ sharing, network permission is required, involving the third-party account's profile photo, nickname, region, gender, and network information. For details, see the Third-Party SDK Directory.

4. Search: When you use Wan Tou Chang Hong search services, we will collect your search keywords and click behavior on results. To provide efficient search services, part of the foregoing information may be temporarily stored on your local device and may be used to show you search results and search history.

5. Payment: We will call a third-party payment institution's SDK to provide services, requiring network permission, read/write external storage permission, and read phone state, involving mobile number, personal identity information, property information, operation logs, network information, device information (Android ID, OAID), operating system, device model, Bluetooth MAC address, operator type, app installation information (read-only UnionPay app), and processes running in this app, including your name, bank card type and number, expiry date, and mobile number. When you use WeChat Pay in the Wan Tou Chang Hong mini program, if your account is not yet bound to WeChat, you must complete "Bind WeChat ID" first (see Section 1.1.6 of this Policy); we will use the bound WeChat OpenID to interact with the payment channel for pre-order placement and payment verification. Bank card number, expiry date, and mobile number are sensitive personal information required for payment. Refusal will prevent you from using the payment feature but will not affect other features.

6. Feedback: When you use the feedback feature, Wan Tou Chang Hong may request photo album permission and read phone state (for calling customer service and uploading screenshots). These are sensitive permissions; refusal will prevent you from using the related features but will not affect other features. If you provide contact information in feedback and expressly agree to a callback, we may contact you for follow-up to resolve your issue, and you may check call records in account security.

7. App updates: When you use app update services, we may request install packages, mount/unmount external files for applications, and restart other apps. Refusal will not affect your use of our other services.

7.1 App basic operation and third-party SDKs (Android/iOS clients)

The Wan Tou Chang Hong app is built on DCloud uni-app. To ensure secure and stable operation, message push, and statistical analysis, the following SDKs are initialized and collect necessary information only after you agree to this Privacy Policy. For SDK name, developer, information collected, purpose, and privacy policy links, see the Third-Party SDK Directory in this Policy:

• DCloud uni-app engine: collects device identifiers (including OAID and Android ID), app launch and crash logs for statistical analysis, performance optimization, and troubleshooting.
• Mobile Intelligent Terminal Supplementary Device Identifier Unified Call SDK: collects OAID for anonymous device identification and statistical analysis.
• Xiaomi Push: collects device identifiers and network information to provide message push services on Xiaomi devices.
• OPPO PUSH Client SDK: collects device identifiers and network information to provide message push services on OPPO devices.
• vivo Push SDK: collects device identifiers and network information to provide message push services on vivo devices.
• Whale Hong Kinetic Energy SDK: collects device identifiers, network information, and app information for Huawei device push and advertising identifier capabilities.

(I) Account security

1. If you forget your Wan Tou Chang Hong Aijijin account password and need to recover it, we need to verify your identity. You must provide identifiable information such as ID number, bank card number bound at account opening, and the mobile number reserved for that bank card.

2. When you use fingerprint payment, your fingerprint information is used for verification. We do not collect your raw fingerprint image; your raw fingerprint image is only stored on the device where you authorized fingerprint collection. Please refer to the Fingerprint Service Agreement you agreed to when enabling fingerprint payment. If you do not wish to verify transactions by fingerprint, you may still use your payment password.

3. To prevent phishing and fraud, protect your account security, guard against social engineering attacks, and improve the security of fund trading services, we may collect your transaction information, device hardware model, and device identifiers (such as android_ID and UDID) to assess account risk, prevent information leakage and financial loss, and analyze system stability and compatibility.

(IV) In addition, when you use services corresponding to Wan Tou Chang Hong Aijijin, we may need to call or use your device capabilities to collect and use your personal information. Before using the services, you may choose whether to authorize us to enable the following permissions:

• (a) Camera: you may enable the camera for identity verification (ID recognition and face recognition login), bank card recognition, photo upload, and video face signing (if applicable);
• (b) Photo album: when you communicate with customer service or submit supporting materials for identity verification, you may select images from your local album. With album access enabled, you may also upload profile photos and post images in Wan Tou Chang Hong Aijijin;
• (c) Location: you may enable location services so that Wan Tou Chang Hong Aijijin, its affiliates, or partners can better comply with regulatory requirements for anti-money laundering and suspicious transaction reporting;
• (d) Microphone: you may use the microphone for voice input and communication in specific scenarios (voice search, voice messages) or video face signing (if applicable);
• (e) Fingerprint / Face ID: you may authorize access to your device's fingerprint or Face ID system to help Wan Tou Chang Hong Aijijin, its affiliates, or partners complete identity recognition, login, verification, rights confirmation, and payment instructions. When you verify by fingerprint or pay, we only collect the verification result, not your fingerprint data;
• (f) Phone: when you encounter difficult issues using Wan Tou Chang Hong Aijijin services, you may one-tap dial customer service; enabling this avoids manually entering the customer service number;
• (g) SMS: when you need to enter SMS verification codes during services, enabling this can auto-read verification codes to avoid manual re-entry.

8. Supplemental description of third-party services

Our services may include or link to information or other services (including websites) provided by third parties. Third-party services may call your device permissions and obtain your relevant information so that you can use corresponding features on different devices or third-party platforms. Different third-party services may request different permissions and obtain different information; we recommend that you refer to the relevant service agreements and privacy policies of those third parties. Please note that before using any such third-party services in Wan Tou Chang Hong software, you should carefully read Wan Tou Chang Hong's Disclaimer. Such third-party services are operated by the relevant third parties. When you use them (including when you provide any personal information to them), you are bound by those third parties' service terms and privacy policies (not this Privacy Policy), and you should read their terms carefully. Please protect your personal information and provide it to others only when necessary. This Privacy Policy applies only to personal information we collect, retain, use, share, and disclose, and does not apply to services provided by any third party or third parties' rules for information use. We are not responsible for any third party's use of information you provide. For personal information collected by third-party SDKs in the above services, see the Third-Party SDK Directory; specifics are subject to those third parties' service terms and privacy policies.

9. Secure operation

9.1 To prevent malicious programs and ensure secure operation as necessary, after you agree to this Privacy Policy we will collect overall app operation, usage and frequency, crash information, performance data, app source, and device information including IMEI, MAC address, Android ID, and OAID.

9.2 We use your account information, device information including Android ID, service log information, location information, and information that our affiliates may share with us with your authorization or as permitted by law, to assess account security, authenticate identity, and detect and prevent security incidents.

10. Marketing and promotion

10.1 Marketing activities: when you choose to participate in marketing activities held by us, our affiliates, or third parties, you may need to provide name, mailing address, contact information, and bank account information (bank name, card number, bank address, account type). This is sensitive personal information; refusal may affect your participation but will not affect other features. Only with your consent will we share such information with affiliates or third parties to provide consistent experience in joint activities or to entrust a third party to deliver rewards in a timely manner.

10.2 Purchasing products or services: when you purchase and use paid products or services jointly provided by us, our affiliates, or third parties (including the "Decision" feature), to associate the paid product or service with you, you need to register and log in to an account (see Section 1 on registration and authentication in this Policy for account-related information), then bind the purchased product or service code with that account.

11. Clipboard

When you obtain Wan Tou Chang Hong services shared by others outside the app (including links, codes, or share codes) and wish to open, share, or link them quickly in Wan Tou Chang Hong, we need to read the clipboard for Wan Tou Chang Hong links, codes, or share codes to identify the service you intend to use.

Please note: to protect your privacy, first, we will not upload personal privacy from your clipboard; it is used only to identify Wan Tou Chang Hong services. Second, to minimize reading, we will ask the operating system whether the clipboard contains specific codes for Wan Tou Chang Hong services (where your OS vendor provides such capability); we read only when the system returns a positive signal.

For a detailed list of personal information we collect, you may refer to Wan Tou Chang Hong's App Personal Information Collection List.

12. Auto-start

To ensure that this app can normally receive client push broadcasts when closed or running in the background, the app must use auto-start capability and may be woken by system broadcasts at a certain frequency. When you open a content push message, with your explicit consent, related content will open; without your consent, there will be no associated startup.

(I) Our handling of minors' personal information

We attach great importance to the protection of minors' personal information. By default, we do not provide services to users under 18. If we discover that a user has impersonated an adult to complete registration without guardian consent, we have the right to immediately freeze or cancel the account and anonymize or delete collected information.

(II) How we collect personal information

• 1. Personal information you actively provide to us when we provide services to you;
• 2. Information generated in the course of providing services to you that relates to those services;
• 3. Collection of your credit and behavioral information from credit agencies, credit management companies, credit assessment institutions, or similar institutions permitted by law or regulation;
• 4. Collection from government agencies, judicial authorities, and public institutions (such as the People's Bank of China, Ministry of Public Security, human resources and social security departments, housing provident fund management centers, the National Internet Finance Association of China, etc.) of necessary information related to services, such as your identity document information, industrial and commercial information, tax information, litigation information, and social insurance information;
• 5. With your authorization, collection from natural persons, legal persons, or other organizations that lawfully retain your information, of information necessary for the services we provide;
• 6. Other methods permitted by you.

(III) How we use personal information

• 1. To provide you with our products or services and to improve those products or services.
• 2. During the period in which we provide services to you, you authorize us to continue collecting and using your information. When you cancel the service, we will stop collecting your related personal information. We will complete account cancellation within 15 business days, and your personal information will be deleted or anonymized; shared third-party information will be notified for deletion in sync, but we may continue to use previously collected personal information for business archiving, auditing, and regulatory cooperation.
• 3. To improve your product or service experience or to prevent risks, we may aggregate, statistically analyze, and process service usage, but such information will not contain any information that identifies you.
• 4. To inform you of your use of our products or services or to help you further understand our services, we may send you service status notifications and commercial information about related products or services. If you do not wish to receive commercial information, you have the right to unsubscribe and require us to stop using your information for that purpose.
• 5. To use your personal information for other purposes permitted by law.

(I) Cookies

To ensure normal website operation, we may store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With cookies, websites can store your preferences or usage habits. We will not use cookies for purposes other than those described in this Policy. You may manage or delete cookies according to your preferences. You may clear all cookies saved on your computer; most browsers provide a function to block cookies. If you do so, you may need to change user settings each time you visit our website.

(II) Web beacons and pixel tags

In addition to cookies, we may use web beacons, pixel tags, and other similar technologies on websites. For example, emails we send to you may contain click URLs linking to content on our website. If you click the link, we will track the click to help us understand your preferences for products or services and improve customer service. A web beacon is usually a transparent image embedded in a website or email. With pixel tags in emails, we can tell whether an email has been opened. If you do not want your activities tracked in this way, you may unsubscribe at any time.

(III) Do Not Track

Many browsers have a Do Not Track feature that can send a Do Not Track request to a website. Major internet standards organizations have not yet established policies on how websites should respond to such requests. However, if your browser enables Do Not Track, all our websites will respect your choice.

(IV) Recommending, displaying, and pushing content you may be interested in

We may use such technologies to understand your preferences and usage habits, conduct data analysis, and improve products and services. On some Wan Tou Chang Hong pages, we use cookies to record browsing activity to recommend information to you and to investigate crashes, delays, and other anomalies and explore better service methods.

(I) Storage

• 1. Personal information we collect and generate within the territory of the People's Republic of China will be stored within China. However, for cross-border business processing and with your separate authorization and consent, your personal information may be transferred abroad. In such cases, we will take effective measures to protect your information security, such as de-identifying data before cross-border transfer, or requiring overseas institutions to keep your information confidential through agreements and verification measures.
• 2. We will only retain your personal information for the period required by laws and regulations and for the period necessary to achieve the purposes stated in this Policy, and will determine the maximum retention period for individual user data and the retention period for user logs.

(II) Sharing

We will not share your personal information with any other company, organization, or individual, except in the following circumstances:

• 1. After obtaining your separate consent or authorization, we may share your personal information with other parties.
• 2. We may share your personal information externally as required by laws and regulations or by mandatory requirements of competent government authorities.
• 3. In accordance with laws and regulations and commercial practice, in transactions such as mergers, divisions, or asset transfers, if personal information transfer is involved, we will require the new holder of your personal information to continue to be bound by this Privacy Policy; otherwise we will require that company or organization to seek your authorization again.

Regulatory traceability: On July 18, 2013, the China Securities Regulatory Commission (CSRC) issued the Provisions on Strengthening the Administration of Client Trading Terminal Information and Other Client Information of Securities and Futures Business Institutions; on March 20, 2020, the China Securities Investor Protection Fund Co., Ltd. formulated the Technical Specifications for Securities Companies' Client Trading Terminal Information Management, which was approved by the CSRC. Under these two documents, securities trading must report hardware information to securities companies for traceability; otherwise the trading is non-compliant. Corresponding business functions and types include: trading orders, bank-securities transfers, account login, and password changes. Collected information: mobile terminals are mainly divided into iOS and Android by operating system. Required information: for iOS, mainly IDFV, registered mobile number, actual mobile number used, public IP, public IP port, MAC address, and intranet IP; for Android, mainly IMEI, registered mobile number, actual mobile number used, public IP, public IP port, MAC address, and intranet IP; for other systems, mainly registered mobile number, actual mobile number used, public IP, public IP port, MAC address, and intranet IP.

Please note: although trading trace data is described as "shared," Wan Tou Chang Hong does not lawfully control such data. We only provide technical assistance to securities and futures business institutions for trading traceability and do not store or use such data.

For details on shared information, see the List of Shared Personal Information.

(III) Public disclosure

We will publicly disclose your personal information only in the following circumstances:

• 1. With your prior separate consent or authorization;
• 2. As required by laws and regulations or by mandatory requirements of competent government authorities, we may publicly disclose your personal information.

(I) We have used industry-standard security measures to protect the personal information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data. We will take all reasonable and feasible measures to protect your personal information. For example, we use encryption technology to ensure confidentiality; we use trusted protection mechanisms to prevent malicious attacks; we deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we conduct security and privacy protection training for employees to enhance awareness of the importance of protecting personal information.

(II) Please understand that, due to technical limitations and possible malicious attacks, there may be situations we cannot reasonably foresee, prevent, avoid, or control. The internet is not an absolutely secure environment. Please use a strong password to help us keep your account secure.

(III) In the event of a personal information security incident, we will, as required by laws and regulations, promptly inform you and interested parties of the relevant situation by email, letter, telephone, push notification, or other reasonable and effective means, or issue an announcement. At the same time, we will report the handling of personal information security incidents in accordance with regulatory requirements.

(IV) We have established a personal information protection team and an independent body with a personal information protection officer. You may contact them at feedback@invx.top (email). Office address: Room M, 2nd Floor, Building 2, No. 715 Yingshun Road, Qingpu District, Shanghai. Please note that we may not respond to questions unrelated to your personal information rights.

(I) Access, correct, and update your personal information

You have the right to access, correct, and update your personal information through our official website, mobile app, and other channels, except as otherwise provided by laws and regulations. You are responsible for updating your personal information in a timely manner. In the personal center and profile, you may edit your profile photo, nickname, gender, follow list, published content, and personal signature. In account security, you may manage bound email, mobile number, third-party accounts, identity verification, and risk assessment.

(II) Deletion of your personal information

In the following circumstances, you may request us to delete personal information:

• 1. If our processing of personal information violates laws and regulations;
• 2. If we collect or use your personal information without your consent;
• 3. If our processing of personal information violates our agreement with you;
• 4. If our processing purposes have been achieved, cannot be achieved, or are no longer necessary to achieve the processing purposes;

If we cease operations, we will promptly stop collecting your personal information, notify you of the cessation of operations by individual delivery or public announcement, and delete or anonymize your personal information we hold.

(III) Account cancellation, withdrawal of consent, and other controls

• (1) Account cancellation. In the app: Home — Personal Center — Account Security; follow the instructions or contact customer service to cancel your account. After cancellation, we will delete or anonymize your personal information;
• (2) Withdrawal of consent. In the app: Home — Personal Center — Settings — About — at the bottom of the Privacy Policy page, you may withdraw consent; in Settings you may also manage permissions and revoke previous system authorizations;
• (3) Managing app usage information. In the app: tap the search bar — clear history; in system settings — clear cache.

If you cannot access or edit your personal information through the above paths, you may contact us at any time by phone (18555332009) or email (feedback@invx.top), and we will reply and provide guidance as soon as possible.

(IV) Responding to your requests

For security, we will first require you to verify your identity before processing your requests; please understand. We may refuse requests that are not directly related to your identity, are repeated without reasonable grounds, require excessive technical means, pose risks to others' lawful rights and interests, or are impractical.

• 5. Responding to your request would cause serious harm to your or other individuals' or organizations' lawful rights and interests;
• 6. The request involves our trade secrets.

1. DCloud uni-app engine

Developer: DCloud (Beijing) Network Technology Co., Ltd.

Information collected: device identifiers (including OAID and Android ID), app launch and crash logs

Purpose: app framework operation, statistical analysis, performance optimization, and troubleshooting

Privacy policy: https://dcloud.io/license/appprivacy.html

2. Mobile Intelligent Terminal Supplementary Device Identifier Unified Call SDK

Package name: com.bun.miitmdid

Developer: China Academy of Information and Communications Technology

Information collected: OAID (Open Anonymous Device Identifier)

Purpose: obtain anonymous device identifiers for statistical analysis and app security

Privacy policy: https://www.msa-alliance.cn/col.jsp?id=122

3. Xiaomi Push

Package name: com.xiaomi.push

Developer: Beijing Xiaomi Mobile Software Co., Ltd.

Information collected: device identifiers (such as OAID and RegId), network information

Purpose: provide message push services on Xiaomi devices

Privacy policy: https://dev.mi.com/console/doc/detail?pId=1822

4. OPPO PUSH Client SDK

Package name: com.heytap.msp

Developer: Guangdong HeyTap Technology Co., Ltd.

Information collected: device identifiers (such as OAID and RegistrationID), network information

Purpose: provide message push services on OPPO devices

Privacy policy: https://open.oppomobile.com/new/developmentDoc/info?id=11228

5. vivo Push SDK

Package name: com.vivo.push

Developer: vivo Mobile Communication Co., Ltd.

Information collected: device identifiers, network information

Purpose: provide message push services on vivo devices

Privacy policy: https://dev.vivo.com.cn/documentCenter/doc/878

6. Whale Hong Kinetic Energy SDK

Package name: com.huawei.hms.ads

Developer: Huawei Software Technologies Co., Ltd.

Information collected: device identifiers, network information, app information

Purpose: Huawei device push and advertising identifier capabilities

Privacy policy: https://developer.huawei.com/consumer/cn/doc/HMSCore-Guides/whale-hong-kinetic-energy-sdk-privacy-statement-0000001658283582