Contents

I. How do we collect and use your personal information

II. How do we share and disclose your personal information

III. How do we store and protect your personal information

IV. Your rights and options

V. Protection of minors

VI. About this Policy

VII. Contact us

VIII. Dispute resolution

I How do we collect and use your personal information

A. Collection

We will collect and use some of your personal information while you are using LumiReels services. The type and manner of personal information that we collect and use depend on the way you use our services and we may collect your information via different ways.

Information you provided

(1) Account information

When you register or log in, we will collect your personal information, including your phone number or email, password and birthday. You may fill in relevant information such as your gender, nickname. You should ensure the correctness of such information. We collect such information to provide account registration and log-in services and to protect your account and complete your online profile.

(2) Information exchange

When you post a text comment on a video, we will collect the text content and associated metadata (such as comment sender, sending time and IP address). We do this to ensure that comments are displayed normally, and to achieve the aims of confirming content security, detecting crimes and protecting our users.

(3) Photo information

When you are asked to take a photo or choose one from the album for your profile photo or other services, we will require the access to your camera or album, and collect the photo/video information you provided and the associated metadata (such as photo sender, sending time and IP address). If you refuse to provide such access, you cannot use this specific function, without prejudice to your access to other functions of the product and/or service.

(4) Survey and promotion information

If you participate in any of our surveys, promotions, contests or marketing campaigns, we will collect your information provided, such as your name, contact and address.

(5) Information you provide when contacting us

When you contact us, to ensure your account and system safety, we may require some of your personal information first for verification. Upon verification, we will provide you with customer service based on your contact (phone number/email/other contact), your communications with us (including text/picture/audio and video) and other necessary information related to your request. During this period, we will collect the personal information you provided, so as to solve your problems.

Information we automatically collected

(1) Equipment information

When you access our services, we will automatically collect your equipment information including your IP address, equipment type, model, name, advertising ID, device ID, browser type and setting, operating system, language setting, mobile network information (including operator name and phone number), APP version, storage and other IT information. We collect such information to realize the most basic product and service functions, protect your account and system and provide continuous, stable and consistent services to you.

(2) Usage Information

When you use LumiReels services, we will automatically collect the information such as the video you’re watching, words (including voices) you searched, times you browse videos and advertisements and interact with them, your duration and frequency of using our service, your interactions with other users, your purchase information, information you favor/share, your profile (e.g. your age, gender, interest and hobby) and/or other information regarding your interactions with our website. We collect such information to provide you with the contents you need. Meanwhile to better understand users, we will use such information to analyze your appetite for videos, so as to recommend you in real time quality videos and advertisements that you might be interested in.

(3) Your location information

We will collect your location information while you use our services to enable certain practical functions, such as recommending quality videos and advertisements in your area. We will roughly infer your location based on IP address.

(4) Log information

We will automatically collect the logs when you use LumiReels services, which might be obtained via using Cookie, web beacon, log file, programming script, e-tag or other manners. Please read the Cookie Terms in Section C, Chapter I of this Policy if you want to know more about how we use Cookie and other similar technologies.

Information from a third party

(1) Third-party account information

If you use the account of a third-party platform (such as Facebook/Google/Apple ID) to log in our services, we will obtain your account information from such platform (including your name, profile photo, phone number, email specifics, subject to your authorization), so as to create or log in LumiReels account, provide services enjoyed by log-in users, protect your account and prevent security risks.

(2) Third-party payment agency information

If you purchase our VIP services or other contents, the third-party payment service providers working with us (such as Apple pay, Google pay and MasterCard) will provide us with your payment information or its updated information, so as to verify your payment status and proceed with your paid services. Please note that we collect only the information of your purchased product, payment serial number and channel ID, not your bank account number, payment password or other payment information.

(3) Information obtained from public sources

For example, government published data and public data on social media platform.

(4) Information obtained from other sources

You acknowledge that we must not and will not obtain any of your personal information from a third party without your authorization. If we need to obtain your personal information indirectly from a third party due to business cooperation and the like, we will ensure lawful collection and use of such information on multiple levels and by multiple means: (1) we will take measures including but not limited to signing contracts to ensure as much as possible that such third party has obtained your consent or is collecting your personal information within the scope permitted by relevant laws and regulations; (2) we (or the third party) will explicitly present to you the source, type, purpose and manner of use, business function and scope of authorization of relevant personal information (we will obtain your consent again if the manner and scope of use exceed the original authorization); (3) ask the third party to commit to the lawfulness of the source of personal information by an agreement or others, and if such third party violates the agreement, we will explicitly demand the bearing of relevant responsibilities; (4) our professional security team will improve the guard for personal information. We will protect the personal information indirectly obtained with the equal protection means and measures no less than the level we did with our own users.

B. Use of personal information

We will use the information collected from LumiReels services for the following purposes according to the type of relevant information:

（a） Conclusion and performance of an agreement with you and execution of the agreement there between;

（b） Provision, processing, maintenance, R&D and improvement of LumiReels services (including video content, advertisement and paid services);

（c） Provision of personalized recommendations (including video content and advertisement);

（d） Evaluation of your application (if relevant) and reply to your question/consultation/feedback/dispute;

（e） Handling of your registration and log-in request, verification and performance of your transactions related to online payment;

（f） Permission to participate in platform interactions (such as commenting on videos);

（g） Communication with you, including sending you commercial promotion information, operation activity notifications and updates to your agreement. Regarding one or more contact information provided by you or collected by LumiReels in LumiReels services (such as email, phone number, e-message and address), we may contact you during operation and send you security verification information, product and service updates, along with activity details, discounts, user experience surveys, etc. You can unsubscribe using the method described in Section (5), Chapter IV of this Policy.

（h） Monitoring, prevention or investigation of any fraudulent or abusing acts, security risk or technical issues damaging LumiReels, you or the public, protection of your account and system security and improvement of the security and reliability of LumiReels services;

（i） Market survey and trend analysis, and comprehensive statistics, data analysis, processing and investigation related to LumiReels services.

（j） Other purposes that we disclose to you separately when collecting your information, or any other purpose to which you consent.

C Cookie Terms

Cookie is a small file containing character strings sent to or stored in your computer, mobile equipment or other devices while you log in and use websites or other network contents (usually after encryption). Similar technologies of Cookie refer to ones with similar purpose with Cookie, such as Web Beacon, Proxy and inserted script. In this Policy, we will refer to such technologies collectively as “Cookie”. Generally, we will use Cookie to collect your personal information during registration, log-in and use of our services, such as your habits of visiting websites, your browsing history and log-in information.

We use Cookie mainly for simplifying relevant operations (such as remain logged in), protecting your account and our products, measuring and analyzing the pages you clicked on and your platform usage, recording your preferential settings, recommending contents that meet your personal needs and might interest you, improving website performance, monitoring our website traffic and operations, and measuring, analyzing and optimizing advertising performance on our platform, so as to improve user experience and our services.

You can manage or delete the Cookie already stored in your computer, mobile equipment or other devices via related functions of your browser or other equipment. Part of our services can only be available with Cookie and if you refuse or delete it, you may not use relevant services or obtain optimal service experience, meanwhile it also may affect the protection of your information and account.

II How do we share and disclose your personal information

1. Sharing Your sharing

You can share your personal information or other information with any third party (including unspecified objects) based on LumiReels services. For example, you can choose email, SMS, social APP (such as Facebook) or other applications to share relevant information when you using the sharing function of our services. The information you shared to any third-party applications will be controlled and processed by such third party, subject to its service terms and privacy policy. You should solely bear the responsibility for any disclosure, misuse or similar circumstances due to your sharing and we shall bear no responsibilities in this regard.

2. Our sharing

We usually don’t share your personal information with any third party, except in one or multiple of the following circumstances where we will do such as per the legal requirements of your judicial jurisdiction:

2.1 Where you make the proposal to share or prior consent of sharing has been obtained;

2.2 Sharing with business partners

You understand and agree that some of our services will be provided by our business partners or jointly therewith, and that you agree that we can share your necessary personal information with the following partners for the sake of this Policy:

a. service provider, such as promotion agency, payment agency, logistics provider, other partners providing services including Apple pay, Google pay .

b. data processor (including the one providing such services as online advertisement data monitoring, data statistics and data analysis), to analyze/maintain/improve our services and offer you better contents, we may share your relevant information with designated partners (such Google) providing such services in a summarized manner (such as video play record, advertisement display record, terminal model and your local city). Where the aforesaid information involves no personal information, please be assured that unless with your consent, we will never share your personal information;

c. advertisement partners, for example, during our cooperation with Google concerning advertisement putting, we will share your device ID, advertising ID, user age and gender tag and IP address with them, so as to help with advertisement or decision-making process, improvement of the advertisement effectiveness and further understanding of user needs. A privacy identifier means that we will convert original information (e.g. email or phone number) into values to prevent original information leakage. We promise that without your consent, we will never share any information that will identify you.

d. service partners of operation activity, for example, we will share the information of any winner (e.g. your name and other information) in the joint marketing activity with a third party, so that such third party can send you the reward/present in a timely manner;

e. third party SDK provider: our product may contain third party SDK or other similar applications; if you use such services provided by third party on our platform, you agree to its direct collection and processing of your information (by such ways as insert code or widget). The collection and processing of information by such provider follow its own privacy provisions, not this Policy. However, we will also do our best in examining the access qualification of such third party and impose lawful, compliant and secure requirements thereon. To protect your information security to the maximum, we strongly recommend you to first read its privacy provisions before using any third-party SDK. To ensure your lawful rights and interests, if you discover the risks of any such SDK or similar application, we suggest you immediately cancel relevant operations and contact us in time.

When sharing your information, we will take multiple measures to protect your personal information, including but not limited to (1) where necessary, we will obtain your authorization and consent upon notifying the purpose, type and receiving party of relevant information before sharing; (2) we will use an agreement to strictly ensure that the information receiving party observes the duties and bears legal responsibilities concerning protection of personal information; (3) our security team will conduct security evaluation and processing as to the manner, transfer, use, etc. of the information and try to make the personal information anonymous; (4) where the aforesaid sharing involves possible transmission of your information to other countries/regions, whether it’s to our related companies or any third party partner, we will abide by relevant applicable laws and regulations to ensure that this type of information satisfy local legal requirements for data protection.

2.3 Sharing under legal provisions or regulatory requirements

(1) Under certain circumstances, we may, as required by the law or regulators, share your personal information with a third party (such as judicial authority, law enforcement agency, government organ or other similar entity), in order to protect your and our lawful rights and social public interests or prevent relevant property or security from damaging;

(2) In certain cases where only by sharing your personal information can our services be available or the services you required available, or settlement of relevant dispute or controversy involving you be possible;

(3) Sharing your personal information as per relevant agreements signed with us (such as online agreement or platform rules) or legal documents;

(4) The information we shared is one that’s unidentifiable where the third party receiving such information cannot re-identify the owner of the information, or you make public at your discretion, or we obtained from legal and public channels;

(5) Other circumstances stipulated by other laws and regulations or required by regulators.

2.4 Any third party related to certain transactions

If we’re engaged in a merger, acquisition, reorganization, division, bankruptcy, transfer of asset or similar transaction and your personal information may be transferred as part of the deal, we will notify you in this regard and demand the new holder of the information abide by and perform any and all contents of this LumiReels Privacy Policy (including purpose and rules for use and security protection measures).

Disclosure of personal information

Except for necessary disclosures based on proper causes such as punishment announcement of violating account and fraudulent acts, publishing relevant information of the winner list, abiding by court decision or other legal procedures, following the requirements of relevant government organs or statutory authorized organizations or according to law, we will not disclose your personal information and where the situation requires, we will notify you of the purpose and type of disclosure and obtain your consent before disclosing your information to the public.

Please note that even if with your authorization and consent, we will only disclose your personal information in a lawful, just, necessary, specific and clear manner and try to make the disclosed information unidentifiable.

III How do we store and protect your personal information

A. Storage

a. location: presently, LumiReels sets up a data center in Singapore. You understand and agree that, under the conditions and terms of this Policy, we may transmit and store your personal information to/in such data center upon compliance of applicable laws and regulations. Though the standard for protection of personal information may vary in the location of data center and the judicial jurisdiction area of your place, we will do our best to protect your personal information with stricter standard and make the biggest effort possible to prevent the disclosure of your information.

As stated in this Policy, we may share your personal information with third parties, who may be located outside Singapore. We will not transmit your personal information until we have complied with the applicable laws and regulations regarding cross-border transmission.

b. period: generally, we only need to store your personal information in the shortest period of time possible for provision of our services and after such period, we will delete or anonymize your personal information as per the requirements of relevant laws and regulations. However, in the following circumstances, we may alter the period for storage of information due to relevant legal requirement:

（1）to follow relevant provisions of applicable laws and regulations;

（2）to follow court decision, ruling or other legal procedures;

（3）to follow the requirements of relevant government organs or statutory authorized organizations;

（4）we deem necessary to follow relevant provisions of laws and regulations;

（5）for proper and necessary purposes to execute relevant service agreement or this Policy, maintain social public interests, and protect the personal and property safety of us, our related companies, our partners, other users or employees, or to protect other lawful rights and interests.

Especially, if you’re a Canadian user and we made decisions that directly affect you upon using your personal information, we will keep such information for at least one year after such use, so that you may access such at the appropriate time. Even if you change or cancel the consent for our collection, use, sharing or disclosure of your personal information, we can still keep such information if having proper legal grounds.

When our product or service stops operating, we will notify you by, among others, push notification or announcement and will delete or anonymize your personal information within proper period.

B. Protection

We adopt multi-dimensional protection measures to protect your personal information including security technology conforming to industrial standard and supporting organizational structure and management system, so as to reduce the risks to the minimum of disclosure, damage, misuse, unauthorized access, unauthorized disclosure and alternation of your information.Specific protective measures include the following:

1. Technical measure for data security

We adopt encryption technology such as security agreement on the transmission layer to prevent the transmission from being sniffed, bugged or intercepted; adopt security storage measures such as classified and layered disposal of data; adopt strict data access control system, adopt multiple identity certification technology, monitor data processing to avoid illegal access and unauthorized use of data; monitor and audit the entire lifetime of data to prevent unauthorized access, disclosure, use, alternation, man-made or accidental damage or loss of personal information.

2. Data security organization and management measures

We establish special department for personal information protection and formulated relevant internal control management system to minimize employee authorization such as the standard for secure use of business data and standard management system of data cooperation; organize employees to participate in relevant security protection training on a regular basis and take other practicable security organization and management measures, such as locking the storage area of personal information and restricting employees’ access to the storage area.

3. Handling of security incidents

We set up an LumiReels emergency response center and formulated several security management rules and emergency response plans. In case of personal information security incident, we will activate the emergency preparedness plan (EPP) to prevent it from expanding and notify you by notice, push notification, public announcement and email.

Please note and understand that the Internet cannot be absolutely secure. Despite the aforesaid protection measures taken, we still cannot guarantee or promise with 100% certainty the security of our services or of any information provided by you. If your personal information is leaked, your personal or property security may be affected. Therefore, we strongly advise you to assist us in protecting your account security by secure manner or using complicated password. Upon discovering the leakage of your personal information, please contact us immediately so that we can take relevant measures to protect your information security.

IV Your rights and options

You possess all the rights under applicable laws and regulations regarding your personal information in LumiReels services, and are free to make numerous decisions, including but not limited to the following:

（1）Right to access your personal information

You may inquire or access your relevant personal information in LumiReels services either by directly contacting us, or via our product. The information query and access functions provided by our product include the following:

Inquire/access account information: You can log in to your personal account at any time through related product page to access the personal information in your account including profile photo, nickname, birthday and gender;

Inquire/access usage information: You can inquire part of your usage information at any time through the related product page, including collection history, viewing history and offline downloads.

（2）Right to rectify/alter your personal information

You may rectify/alter part of your personal information by following the operation guide and settings on relevant product pages in LumiReels services. In addition, you can contact us to directly modify or alter your personal information.

（3）Right to delete your personal information

You may delete your relevant personal information in LumiReels services, either by directly contacting us, or via our product. The delete functions provided by our product include the following:

Delete account:

Delete account: You may remove any content from your account either by contacting us directly, or through the built-in online account deletion function

You understand and agree that once you delete your personal information from LumiReels services by yourself or with our help, we may not immediately delete your information from the backup system subject to applicable laws and regulations and relevant security technology, in which case, we will store your personal information in a secure manner and separate such from any further data processing, till such information is deleted or anonymized during the update of our backup system.

（4）Miscellaneous

If you encounter any trouble in exercising such right, you may contact us via the contact information provided herein and we shall help you solve the issue upon verification of your identity within proper period or the period prescribed by the law of your judicial jurisdiction area, unless otherwise stipulated by the applicable laws and regulations or as otherwise agreed upon in this Policy. Other than the rights mentioned above, if the law of your judicial jurisdiction area grant you any other rights concerning personal information, we will do our best to ensure the exercising of such.

V Protection of minors

You must be at least 18 years old to become a member of the LumiReels services.

We value the protection of personal information of minors very much. The age classifying minors and relevant rules for minor privacy protection vary in different judicial jurisdictions. If you achieve the age of 18 but still be a minor under local law, you shall read this Policy under the guardianship and guidance of guardians and submit relevant personal information after the consent of guardians to this Policy and submission. Please note that, considering the features of the Internet and online anonymity of user, we find it hard to verify each and every consent of guardian. For such matter, please first obtain the consent of your guardian voluntarily if you fit in the aforesaid circumstances.

If you believe that we have collected personal information of minors without obtaining their consent, please contact us via the contact information set forth in this Policy.

VI About this Policy

（1. Scope of application

Our services may be provided by or apply features operated by third-party platforms, or they may contain links to or link to websites operated by third parties whose information processing rules are determined by these third parties and may differ from ours. Since these third-party websites, applications and platforms have their own separate and independent privacy policies, this Policy does not apply. Therefore, we advise you to read their privacy policies carefully. For example, when our mobile app contains links to websites operated by third parties, we will inform you or mark them as “third-party products”, “third-party services” or with similar expressions.

2. Update

Based on the ongoing innovation and development of LumiReels’s business mode and technology, we may update the terms of this LumiReels Privacy Policy from time to time. We will, in accordance with applicable laws and regulations, notify you in one or more manners including announcement, push notification, pop-ups, email or any other means so that you can view our new Privacy Policy prior to choosing to continue using our services, then decide whether to continue using our services accordingly. If such updates involve collection of more personal information, or changes in the purpose or manner of using/sharing personal information or the receiving third party, we will again obtain your authorization and consent. We advise you to look up this Policy every time you use our services. To find the last updated date of this Policy, please refer to “Current Version Update Time” at the top of the page.

VII Contact us

（1）If you encounter any issue related to privacy protection or this Policy (including problem consultancy, complaint and advice) during use of our services, you can submit online feedback or contact our data protection officer via:

Email：LumiReels.app@gmail.com

（2）Upon receiving your issue, we will, upon verification of your identity, reply to you within the period prescribed by the law of your judicial jurisdiction area on response and generally, we will not charge any service fee in this regard.

VIII Dispute resolution

If any court of law, having the jurisdiction to decide on this matter, rules that any provision of this Policy is invalid, then that provision will be removed from this Policy without affecting the rest of this Policy. The remaining provisions of this Policy will continue to be valid and enforceable.

Any disputes that raised out of or related to this Agreement, including but not limited to carrying out the provisions of this Agreement, shall be negotiated by both parties through amicable settlement.