UYOLE Meeting Voice Recorder User Privacy Policy

1. Definitions and Interpretation

1. UYOLE Product: Refers to the product combination including the AI meeting voice recorder hardware and the supporting UYOLE mobile application, with functions such as recording, AI translation, recharge payment, and built-in battery power supply.
2. Personal Data: Refers to information that can directly or indirectly identify a user's identity, as defined by the EU General Data Protection Regulation (GDPR) and relevant U.S. privacy laws, including but not limited to audio recordings, recharge account information, device identifiers, etc.
3. Data Processing: Includes all operational behaviors such as collection, storage, transmission, use, encryption, anonymization, and deletion of personal data.
4. User: Refers to a natural person who purchases, activates, or uses the UYOLE Product (excluding legal persons and other organizations).

2. Scope of Application

1. This Policy covers all personal data processing activities generated during the user's use of the UYOLE Product, including hardware-side recording storage, APP-side AI translation, recharge transaction records, etc.
2. This Policy does not apply to independent services provided by third parties through the UYOLE Product; third-party services shall be governed by their own privacy policies.

3. Data Collection and Use

(1) Types and Purposes of Collected Information

1. Audio Data:
   1. Collected only after the user actively enables the recording function and confirms authorization, for the purpose of realizing meeting recording, local storage, and subsequent AI translation services.
   2. Text data generated during translation is only used to generate translation results and is not additionally associated with user identity information.
2. Account and Recharge Information:
   1. Collects the email address/mobile phone number provided by the user during registration (for account verification), recharge amount, and transaction records, solely for ensuring the effectiveness of paid services and subsequent invoice issuance.
3. Device Information:
   1. Collects device serial number and firmware version (non-identifying information) to provide device updates and troubleshooting services; no irrelevant data such as reverse charging usage records is collected.

(2) Collection Principles

1. Strictly adhere to the principle of data minimization and do not collect any information irrelevant to the core functions of the product.
2. All information collection is subject to the user's explicit authorization; the recording function requires the user's secondary confirmation via hardware buttons or APP pop-ups.

4. Data Storage and Security

(1) Storage Specifications

1. Storage Location:
   1. User data is stored on servers located in Singapore.
   2. Local recording data is preferentially stored in the device's built-in storage and is only uploaded to the corresponding regional cloud server when the user actively synchronizes.
2. Storage Period:
   1. Audio Data: If not actively deleted by the user, the local storage period is consistent with the device's usage cycle, and the cloud storage period shall not exceed 2 years; it will be automatically and permanently deleted after the expiration period or when the user cancels the account.
   2. Recharge Records: Retained for 7 years after transaction completion (in compliance with European and American financial regulatory requirements) and anonymized upon expiration.

(2) Security Safeguards

1. Transmission Security: Audio and account data are transmitted encrypted using the TLS 1.3 protocol, and cloud storage uses the AES-256 encryption algorithm to ensure data integrity.
2. Access Control: Only authorized technical personnel can access user data, and multi-factor authentication is required; regular system security audits and vulnerability fixes are conducted.
3. Breach Response: In the event of a data breach, affected users and relevant regional regulatory authorities (such as the European Data Protection Board, U.S. FTC) will be notified within 72 hours, and remedial measures will be provided.

5. Data Transmission and Sharing

1. Cross-border Transmission: Conducted only with user authorization and in compliance with the compliance framework; data transmission from the EU region to overseas requires certification through Standard Contractual Clauses (SCC).
2. Third-Party Sharing:
   1. Necessary transaction information is only shared with third parties providing payment services (such as PayPal, Stripe), who are required to comply with equivalent privacy protection standards.
   2. Without the user's written consent, identifiable audio data or account information will never be shared with any commercial institutions.

6. User Rights

Pursuant to the GDPR and relevant U.S. regulations, users enjoy the following rights, which may be exercised through the UYOLE APP "Settings - Privacy Center" or the customer service email (yuanshaoqing@youyouletech.com):

1. Right to Access and Inquiry: View the storage location, usage records, and recharge details of personal audio data at any time.
2. Right to Correction and Deletion: Apply for correction of incorrect account information; initiate a deletion request for audio data at any time, which will be processed within 15 working days.
3. Right to Withdraw Consent: Turn off recording authorization through device settings; the recording function will be immediately disabled after withdrawal, and stored data will not be affected.
4. Right to Data Portability: Apply to export audio and translated text data in common formats (such as OGG, mind maps).

7. Applicable Law and Dispute Resolution

1. Applicable Law: EU users are subject to the GDPR and the privacy laws of their member states; U.S. users are subject to the California Consumer Privacy Act (CCPA) and Federal Trade Commission privacy rules.
2. Dispute Resolution: Disputes arising from this Policy shall be resolved through friendly negotiation first; if negotiation fails, EU users may file a complaint with the data protection authority of their country, and U.S. users may submit to a court with jurisdiction in the product's sales location for litigation.

8. Miscellaneous Provisions

1. When this Policy is updated, users will be notified via UYOLE APP pop-ups, and continued use of the product by the user shall be deemed acceptance of the updated content.
2. The product's reverse charging function only involves device power transmission and does not collect any user data related to charging.
3. Matters not covered by this Policy shall comply with the currently valid privacy protection laws and regulations of the target market.
4. Recharges for large model transcription duration and membership upgrade recharges within this application are all payments to the large model, and no refunds will be supported once the payment is successful.