Privacy Policy for Application

Privacy Policy

This Policy applies solely to the "Mivsn Panel", "Mivsn Mic Panel" and "mivsnPanel" of Shanghai Mivsn Electronic Technology Co., Ltd. and Shenzhen Mivsn Electronic Technology Co., Ltd. Last Updated: September 1, 2026

This Policy will help you understand the following:

1. How we collect and use your user information

2. How we use Cookies and similar technologies

3. How we share, transfer and publicly disclose your user information

4. How we protect your user information

5. Your rights

6. How we handle children’s personal information

7. How your user information is stored and transferred globally

8. How this Policy will be updated

9. How to contact us

We fully recognize the importance of user information to you and will do our utmost to keep your user information secure and reliable. We are committed to maintaining your trust and protecting your user information by adhering to the following principles: principle of consistent rights and liabilities, clear purpose principle, consent-by-choice principle, minimum-necessary principle, security assurance principle, subject participation principle, and openness and transparency principle. Meanwhile, we undertake to adopt corresponding security protection measures in accordance with mature industry security standards to protect your user information.

Please read and understand this Privacy Policy carefully before using our products (or services).

1. How we collect and use your user information

1.1 Information collected and used when you use our products or services

We collect and use your user information only for the business functions described in this Policy. The purpose of collecting user information is to provide you with products or services. You have the right to choose whether to provide such information. However, in most cases, if you decline to provide it, we may not be able to provide corresponding services or respond to issues you encounter.

After you install and launch our application for the first time, the built-in special effect files (mp3 files) of the application will be extracted to the sandbox directory for the special effect playback function. When you import special effect files via the application, the selected special effect files will also be copied to the sandbox directory.

We will request audio input permission, which is used to obtain audio information from the system when you use the application’s recording function. You may disable this permission if you do not need the recording function.

We will request accessibility permission, which enables the application to capture keyboard inputs and play corresponding special effects via shortcut keys even when the application is not in the foreground. You may disable this permission if you do not require this function.

This application will also request network permission to retrieve online effect lists from Mivsn servers.

We guarantee to de-identify or anonymize the collected user information in accordance with the law. Information that cannot identify a natural person individually or in combination with other information does not constitute personal information in the legal sense. If we combine non-personal information with other information to identify your personal identity, or use it together with your personal information, such information will be treated as your personal information and processed and protected under this Privacy Policy during such combined use.

To better operate and improve our technologies and services, or in response to changes in business strategies, where the collection, use and processing of user information required by our products or services exceeds the scope above, or where collected user information will be used for other purposes not specified in this Privacy Policy, or where information collected for a specific purpose will be repurposed, we will notify you within a reasonable period after obtaining your user information or prior to processing such information and obtain your authorization and consent.

1.2 Exceptions to obtaining authorization and consent

Please note that under laws, regulations and relevant national standards, we may collect and use your user information without obtaining your authorization and consent in the following circumstances:

1. Directly related to national security and national defense security;

2. Directly related to public security, public health and major public interests;

3. Directly related to criminal investigation, prosecution, trial and judgment enforcement;

4. Necessary to safeguard the significant legitimate rights and interests of you or other individuals such as life and property, where it is difficult to obtain consent from the individual;

5. The user information collected is publicly disclosed by you to the public;

6. User information collected from legally publicly disclosed sources, such as legitimate news reports and government information disclosure channels;

7. Necessary for concluding or performing a contract at your request;

8. Necessary to maintain the secure and stable operation of software and related services, e.g., detecting and resolving faults of software and related services;

9. Where the personal information controller is a news agency and the processing is necessary for conducting legitimate news reporting;

10. Necessary for statistical or academic research conducted by academic research institutions based on public interests, provided that personal information contained in the results is de-identified when the research results are published or described externally;

11. Other circumstances stipulated by laws and regulations.

2. How we use Cookies and similar technologies

The Mivsn App does not use Cookies or similar technologies.

3. How we share, transfer and publicly disclose your user information

3.1 Sharing

We will not share your user information with any other companies, organizations or individuals, except in the following cases:

1. Sharing with explicit consent: We will share your user information with other parties upon obtaining your explicit consent.

2. We may share your user information externally in accordance with the provisions of laws and regulations or mandatory requirements of competent government authorities.

3. Sharing with our affiliates: Your user information may be shared with our affiliates. We will only share necessary user information subject to the purposes stated in this Privacy Policy. If an affiliate intends to change the purpose of processing user information, it will seek your authorization and consent again.

4. Sharing with authorized partners: Certain services are provided by our authorized partners solely to achieve the purposes stated in this Policy. We may share part of your user information with partners to deliver better customer service and user experience. We share your user information only for legitimate, proper, necessary, specific and clear purposes, and only share user information necessary for service provision. For better operation and improvement of technologies and services, you agree that we and our authorized partners may use the collected information for other services and purposes subject to applicable laws and regulations.

We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share user information, requiring them to process user information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

3.2 Transfer

We will not transfer your user information to any companies, organizations or individuals, except in the following cases:

1. Transfer with explicit consent: We will transfer your user information to other parties upon obtaining your explicit consent.

2. In the event of merger, acquisition or bankruptcy liquidation involving the transfer of user information, we will require the new entity holding your user information to remain bound by this Privacy Policy; otherwise, we will require such entity to seek your authorization and consent again.

3.3 Public Disclosure

We will publicly disclose your user information only under the following circumstances:

1. After obtaining your explicit consent;

2. Disclosure required by law: We may publicly disclose your user information under laws, legal proceedings, litigation or mandatory requirements of competent government authorities.

3.4 Exceptions to prior authorization and consent for sharing, transfer and public disclosure of information

Please note that under laws, regulations and relevant national standards, we may share, transfer and publicly disclose your user information without obtaining your authorization and consent in the following circumstances:

1. Directly related to national security and national defense security;

2. Directly related to public security, public health and major public interests;

3. Directly related to criminal investigation, prosecution, trial and judgment enforcement;

4. Necessary to safeguard the significant legitimate rights and interests of you or other individuals such as life and property, where it is difficult to obtain consent from the individual;

5. Information publicly disclosed by you to the public;

6. Information collected from legally publicly disclosed sources, such as legitimate news reports and government information disclosure channels.

4. How we protect your user information

4.1

We have adopted industry-standard security protection measures to protect the user 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 user information. For example, data transmission between your browser and the Services is protected by SSL encryption; we also provide HTTPS secure browsing for the website. We deploy encryption technologies to ensure data confidentiality, adopt trusted protection mechanisms to defend against malicious attacks on data, implement access control mechanisms to ensure that only authorized personnel can access user information, and conduct security and privacy protection training to raise employees’ awareness of the importance of user information protection.

4.2

We will take all reasonable and feasible measures to ensure that no irrelevant user information is collected. We retain your user information only for the period necessary to achieve the purposes set out in this Policy, unless an extended retention period is required or permitted by law.

4.3

The Internet is not an absolutely secure environment. Emails, instant messaging and other communication channels with other users are not encrypted. We strongly recommend that you do not send user information through such channels.

4.4

The Internet environment is not 100% secure. We will strive to ensure the security of any information you send to us. Even with all reasonable and necessary measures adopted, it may still be impossible to prevent unauthorized access, theft, tampering or destruction of your user information, which may impair your legitimate rights and interests. Please acknowledge such risks of information networks and accept them voluntarily.

4.5

In the unfortunate event of a user information security incident, we will promptly inform you in accordance with legal requirements, including the basic facts and potential impacts of the security incident, disposal measures taken or to be adopted, recommendations for you to independently prevent and mitigate risks, and remedies available to you. We will notify you of relevant incident details via email, letter, phone call, push notification or other means. Where it is impractical to notify each data subject individually, we will issue announcements through reasonable and effective channels. Meanwhile, we will proactively report the handling of user information security incidents as required by regulatory authorities.

5. Your rights

In accordance with relevant laws, regulations and standards of China, as well as prevailing practices in other countries and regions, we guarantee your exercise of the following rights concerning your user information:

5.1 Access your user information

You have the right to access your user information, subject to exceptions stipulated by laws and regulations. If you wish to exercise your data access right, you may access it by contacting Mivsn Official: 4008800992.

If you cannot access such user information via the above channel, you may contact us via our Web Form at any time or send an email to riochen@mivsn.com. We will respond to your access request within 30 days.

For other user information generated when you use our products or services, we will provide it to you provided that no excessive effort is required. If you wish to exercise your data access right, please send an email to riochen@mivsn.com.

5.2 Correct your user information

You have the right to request correction when you find errors in the user information we process about you. You may submit a correction application through the channels listed in Section 5.1 "Access your user information". If you cannot correct such user information via the above channel, you may contact us via our Web Form at any time or send an email to riochen@mivsn.com. We will respond to your correction request within 30 days.

5.3 Delete your user information

You may submit a request to delete your user information under the following circumstances:

1. Where our processing of user information violates laws and regulations;

2. Where we collect and use your user information without obtaining your consent;

3. Where our processing of user information breaches our agreement with you;

4. Where you no longer use our products or services;

5. Where we cease to provide products or services to you.

We will assess your deletion request and carry out corresponding procedures if relevant requirements are met. When you submit a deletion request, we may require identity verification to protect account security. After you delete information from our services, due to applicable laws and security technologies, we may not immediately delete the corresponding information from backup systems. We will securely store your information until the backup can be purged or anonymized.

5.4 Change the scope of your authorization and consent

Certain basic user information is required for each business function (see Section 1 of this Policy). You may grant or withdraw your authorization and consent for the collection and use of user information at any time by uninstalling the App.

After you withdraw consent, we will cease processing the corresponding user information. Please note that withdrawal of authorization and consent may result in consequences such as our inability to continue providing corresponding services or specific functions. However, your withdrawal shall not affect the processing of user information previously performed based on your authorization.

5.5 Restriction on automated decision-making by information systems

For certain business functions, we may make decisions solely through non-human automated decision-making mechanisms including information systems and algorithms. If such decisions significantly impair your legitimate rights and interests, you have the right to request an explanation from us, and we will provide appropriate remedies.

5.6 Response to your requests above

For security purposes, you may need to submit a written request or prove your identity by other means. We may require identity verification before handling your request.

We do not charge fees for reasonable requests in principle. However, for repeated or excessive requests beyond reasonable limits, we may charge a reasonable cost fee at our discretion. We may reject requests that are unreasonably repetitive, require excessive technical resources (e.g., development of new systems or fundamental changes to existing practices), pose risks to the legitimate rights and interests of others, or are impractical. Please also note that we may be unable to respond to certain requests due to security considerations, legal requirements or technical limitations, including but not limited to the following scenarios:

1. Requests related to obligations of the personal information controller under 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 judgment enforcement;

5. Where the personal information controller has sufficient evidence showing that the data subject acts with malicious intent or abuses rights;

6. Requests necessary to safeguard the significant legitimate rights and interests of the data subject or other individuals such as life and property, where it is difficult to obtain consent from the individual;

7. Requests whose fulfillment would seriously impair the legitimate rights and interests of the data subject or other individuals and organizations;

8. Requests involving trade secrets.

6. How we handle children’s personal information

We attach great importance to the protection of children’s personal information. Our products, websites and services are primarily intended for adults. Children shall not create user accounts without the consent of their parents or guardians. Notwithstanding varying definitions of children under local laws and customs, we define children as individuals under the age of 14.

Where children’s user information is collected with the consent of parents or guardians, we will only store, use or publicly disclose such information when permitted by law, upon explicit consent of parents or guardians, or necessary to protect children; otherwise, we will endeavor to delete relevant data as soon as possible.

Given limitations of existing technologies and business models, it is difficult for us to proactively identify children’s personal information. If you discover that we have collected children’s personal information unknowingly or without verifiable prior consent from guardians, please contact us promptly and we will attempt to delete such information upon discovery. We will also delete such information when identified by ourselves, except where retention is required by law.

7. How your user information is stored and transferred globally

In principle, user information collected and generated within the People’s Republic of China will be stored within the People’s Republic of China. We retain your user information only for the period necessary to achieve the purposes and uses described in this Policy and the minimum period required by laws and regulations. Upon expiry of such retention period, we will delete or anonymize your user information in accordance with applicable laws and regulations, unless otherwise stipulated by laws and regulations, or retention for public interests, scientific and historical research purposes, or with your separate authorization and consent is required.

As we provide products and services via resources and servers worldwide, this means that upon obtaining your authorization and consent, your user information may be transferred to jurisdictions outside the country/region where you use the products or services, or accessed from such jurisdictions.

Such jurisdictions may have different data protection laws or even no relevant legislation. In such cases, we will ensure that your user information receives protection equivalent to that within the People’s Republic of China. For example, we will request your consent for cross-border transfer of user information, or implement security measures such as data de-identification prior to cross-border data transfer.

8. How this Policy will be updated

This Privacy Policy may be revised. We will not reduce your rights under this Privacy Policy without your explicit consent. Any changes to this Policy will be published on this page.

For material changes, we will provide more prominent notifications. Material changes referred to in this Policy include but are not limited to:

1. Material changes to our service model, such as purposes of processing user information, types of user information processed, and ways of using user information;

2. Material changes in ownership structure or organizational structure, such as changes in owners arising from business restructuring, bankruptcy or merger and acquisition;

3. Changes to major recipients with whom user information is shared, transferred or publicly disclosed;

4. Material changes to your rights and the ways to exercise such rights in relation to user information processing;

5. Changes to the responsible department, contact information and complaint channels for user information security;

6. Where a user information security impact assessment report indicates high risks.

We will archive old versions of this Policy for your reference.

9. How to contact us

If you have any questions, comments or suggestions regarding this Privacy Policy, please contact us via the following methods: Email: riochen@mivsn.com Tel: 4008800992

We have established a dedicated department for user information protection. You may contact relevant personnel via: mailto:riochen@mivsn.com.

We will respond within thirty (30) days in general.