APUS File Manager Privacy Policy

1. Overview

APUS File Manager (this “Product”) is a file manager product developed, operated and managed by Qilin Hesheng Network Technology Co., Ltd. (“APUS” “We” or “us”). We fully respect and protect users’ personal privacy. While providing you with quality services, we will collect, use, disclose, store and protect your personal data in accordance with this Privacy Policy (the “Policy”).

We will explain how we process your personal data in this Policy and how you may access and control your personal data.

Please completely read and fully understand this Policy before using this Product. If you have any questions about this Policy, or have any complaints or suggestions, please contact us via the methods as described in this Policy. This policy will help you understand the followings:

2. How We Collect and Use Your Personal Data

We may collect your personal data as follows while we are providing services. These data is critical for us to realize various functions of this Product. We will use these data to help us develop and improve our products to provide better services. We will use your personal data in strict compliance with the purposes set forth in this Policy. We will inform you in advance and obtain your consent before we use these data for any other purposes than set forth in this Policy or we use the personal data collected for specific purposes for other purposes.

2.1 Category and purpose of your personal data we collect

This Product is a full functionality file manager product with file browsing, management, sharing, and junk file cleaning services. We will collect different categories of your personal data in different scenarios according to various product features, and will use these data to realize such product features.

2.1.1. Pre-activation service

In order to strictly comply with the laws and policies of the relevant countries or regions, we need to use pre-activation services to know your country or region. During pre-activation, we will send your IP address, country code (MCC), mobile phone language, system version and other information to our server. This information is only used to know your country or region, thus providing you with agreements and services that comply with that country or region. This information will be deleted within a short period of time after knowing your country or region, and will not be permanently saved.

2.1.2. Basic File Management Service

As a file management product, we need to get your files, applications, and storage information for file management. The file information includes: the name, type, size, modification time, path of all files in the mobile phone disk, external SD card or U disk, image information of the image file, photo album, cover image of music and video files, album of music files, music and video file duration and other information. The application information includes: installed application list, application name, installation package size, application icon, application package name, application version name, application version number, application installation package file path, and other information. The storage information includes: storage device list, storage device name, storage device path, SD card total storage space, SD card used storage space, internal storage total storage space, internal storage used storage space, and other information. Reading and displaying files and storing information requires that you agree to the application to use storage permissions. Renaming, modifying, deleting, copying, and sharing files will be performed on your own initiative, and all file data will be local. Processing will not upload.

2.1.3. View File Content Service

In order to conveniently view the content of the document, play music and video, we provide you with the service of viewing the content of the file. The function of viewing the content details needs to obtain your text content information, audio file content information, and video file content information. Text content information, audio file content information, video file content information need your consent before proceeding, and all documents, music and video content will be processed in the local mobile phone memory, we will not upload, store your file content data .

2.1.4. Document Editing Service

The product also provides editing functions for document files. Allows you to modify the contents of the document file on the phone. The document editing function needs to obtain the content you input in the file to provide you with the saving service of the edited file. Storage of your edited files will only take place with your authorization. We will not upload your input .

2.1.5. Turbo Transfer Service

The product provides a speedy transmission function that can help you establish a connection with other mobile phones to send files to other mobile phones easily.

When establishing a network connection, you need to read your network information, device information and account information, including: network connection information, Wifi information, IP address, current system language, current system time, current device Android version number, device model, device Information such as brand, device manufacturer, screen resolution, screen pixel density and other device and network information, as well as account information such as email account number and Google account name stored on the device, to generate the connection device name, and connect to other mobile phones. The above network information, device information, and account information will be used after you authorize it. Wifi information, IP address, device model, and account name information will be sent to other devices during the process of establishing a network connection to identify and adapt your equipment.

For file sharing, we need your file information and address book contact information to provide local file browsing and sending services. The file information includes: the name, type, size, modification time, path of all files in the mobile phone disk, external SD card or U disk, image information of the image file, photo album, cover image of music and video files, album of music files, music and video file duration and other information. The address book information includes the contact avatar, contact name, and contact phone number. The file information is read when you send or browse, and the contact data is read when you actively send or browse. All file information and contact information are read and processed locally and are not sent and uploaded unless you actively send it to other devices.

During the sending process, the product provides a simple instant messaging function and provides a conversational interface for text conversations between devices that have established a connection. The conversation will send text, expressions, files, apps, etc. that you have entered into other people. The Send Dialog feature will send the text, expressions, files, and apps you have entered to other people and will execute them after you authorize and send them on your own initiative. The conversation history will be saved locally for future browsing, but we will not upload any conversation content information for you and other contacts.

The product automatically records the session and transmission history of the sending process and saves it locally so that you can query and browse later. Session and transfer history records include text, expressions, names of transfer objects, transfer file names, transfer times, transfer file sizes, transfer file types, and the number of transferred files. Session and transfer history information will only be saved locally for future browsing. We will not upload your session and transfer history information.

2.1.6. Junk File Cleanup Service

To help you clean up junk files on your phone, we provide a junk file cleanup service that helps you automatically analyze and clean junk files and application caches on your phone. When you use the junk removal service, we need to read application information such as your application list and application cache size, as well as SD card top directories, file types, file sizes, file names, file paths, pictures, music, videos, etc. information. We will automatically help you analyze the junk files on your mobile phone. After your confirmation, it will delete junk files that you think are useless.

2.1.7. Transfer Large Files to SD Card Service

To help you make more reasonable use of the storage space on your phone, the product provides a large file transfer to the SD card service to help you transfer large files from your phone’s internal storage to the SD card. When you transfer large files to the SD card service, we read your file information and storage device information. The file information includes: the name, type, size, modification time, path of all files in the mobile phone disk, external SD card or U disk, image information of the image file, photo album, cover image of music and video files, album of music files, music and video file duration and other information. The application information includes: installed application list, application name, installation package size, application icon, application package name, application version name, application version number, application installation package file path, and other information. The storage information includes: storage device list, storage device name, storage device path, SD card total storage space, SD card used storage space, internal storage total storage space, internal storage used storage space, and other information. File transfer will be completed under your own initiative. All processing will only be performed locally. We will not upload file information.

2.1.8. Web Page Transmission Service

To help you easily manage and transfer files on your phone on your computer, we provide a web page transmission function to help you establish a connection on your computer through the browser and mobile phone, then manage and transfer files on your mobile phone.

When you establish a connection between a mobile phone and a computer, we need your internet connection information, Wifi information, IP, current system language, current system time, current device Android version number, device model, device brand, device manufacturer, screen resolution, Screen pixel density and other device and network information to establish a wireless connection for the mobile computer. The above network information and device information will be used after authorizing, in which Wifi information, IP address, device model, device brand, device manufacturer, screen resolution will be sent to other devices during the establishment of the network connection for identification and Adapt your device.

When browsing and managing files on your computer, we need to get your files, applications, and storage information for file management. The file information includes: the name, type, size, modification time, path of all files in the mobile phone disk, external SD card or U disk, image information of the image file, photo album, cover image of music and video files, album of music files, music and video file duration and other information. The application information includes: installed application list, application name, installation package size, application icon, application package name, application version name, application version number, application installation package file path, and other information. The storage information includes: storage device list, storage device name, storage device path, SD card total storage space, SD card used storage space, internal storage total storage space, internal storage used storage space, and other information. Reading and displaying files and storing information requires you to agree with the storage permissions of the application. Renaming, modifying, deleting, copying, sharing, and downloading files will be performed on your own initiative, and all file data will be processed. Processing between computer and mobile phone will not be uploaded.

The product will automatically record the transmission history in the sending process and store it locally so that you can query and browse later. The transmission history includes the transmission object name, transmission file name, transmission time, transmission file size, transmission file type, and transmission file number information. Transmission history information will only be saved locally for future browsing, we will not upload.

2.1.9. New File Alert Service

To make it easier for you to manage new files on your mobile phone, we have provided a new file reminder service that will prompt you when there are new files on the phone. In order to provide this service, we need to monitor the file addition, lightening, and screen-off events on your mobile phone and read the file type, file name, file path, file modification time, and image file image of your new file, and application activity information such as your application’s name, package name, icon, and time of use. The above events and file information will be used only after you agree to enable the application usage permission and enable the feature. It will be performed locally and will not be uploaded.

2.1.10. Uncommonly Used Application Alert Service

In order to facilitate you to manage files that are not frequently used on mobile phones, we provide application reminder services that are not commonly used service. You will be prompted by a card after entering the file management. In order to provide this service, read application information such as your installed application list, application name, installation package size, application icon, application package name, application version name, application version number, and application installation package file path, and you use the application activity information such as name, package name, icon, and usage time. The above events and file information will be used only after you agree to enable the application usage permission and enable the feature. It will be processed locally and will not be uploaded.

2.1.11. Account Service

The product provides an account log in service. After logging in, you can modify the account information yourself. The information includes your personal profile, gender, nickname, name, mobile number, email, birthday, personalized signature, city or region and address, education experience, interest Hobbies, and career information. You can choose whether to fill sensitive information in your profile. If you do not want to provide personal data publicly, do not post or add this information to your profile. You can also update your information in your profile at any time. We will use the big data algorithm to show you interest-based content and services and advertisements based on the data you provide, such as gender, birthday, hobbies, and career information. The name, mobile number, email address, and address information provided by you will be used , After you use the points mall to exchange physical goods, send goods for you. Through the data such as avatar, nickname, gender, hobbies and personality signature data provided by you, you can display this part of information, including exploration and discovery, theme wallpaper, and friend circle function, and you can establish social relationships with others.

2.1.12. Cloud service

We provide you with a wealth of features and services through cloud service interfaces, such as news, video, navigation, event, website security detection, and product updates. In order to ensure the operation of cloud services, we need to collect some necessary data, including: application information such as application package name, application version, and application installation time; system information such as country code, system language, and system time zone; screen resolution and other devices Information; network information such as operators.

2.1.13. Service quality measurement

In order to measure the quality of service of a product and thus provide you with better services experience and other new services, we will collect the following information during your use of the service, and the information obtained will only be used for this purpose.

Activation information: application information including application package name, application version, and application installation time; system information such as Android ID, country code, system language, system version, system time zone, and Google service version; screen resolution, mobile phone brand, mobile phone model, etc.; Network card information and other devices information; network types, operators and other network information.

Usage information: application information including application package name, application version, and application installation time; system information such as country code, system language, and system time zone; screen resolution and other device information.

2.1.14. Provide stable services

In order to provide you with a stable service, we will collect the following related information for locating, analyzing ,and improving problems in the event of product. And the information is only used for this purpose.

Crash information: When our product crashes, you can choose whether to upload crash information. Then we will get the uploaded crash information, including application name, application version, application installation time, application signature and other application information; country code, system language, system time zone, memory information and other system information; screen resolution, mobile phone brand, horizontal screens, vertical screens and other information; crash process name, crash time, system non-sensitive log at crash, and crash log of this application.

Feedback: If you have any questions or suggestions about this policy, you can give us feedback through the product’s feedback function. We will get your feedback, including email address, feedback content, mobile phone brand, mobile phone model, system version and other information.

2.1.15. Anti-Fraud and Anti-Cheating

To prevent fraud and cheating, in order to ensure the normal operation of our business that provide you with better services and ecological environment, we need to obtain some necessary data, including: application package name, application version, application installation time, application signature and other applications Information; Android ID, country code, startup time, system time, memory information, system version, power, volume information, Bluetooth information, SIM card status and identification information, storage information and other system information; screen resolution, mobile brand, mobile phone Type, sensor information, camera information, CPU information, GPU information and other device information; location information, headset pluggable information, application installation and use information, screen unlocking information, Wi-Fi list information, network information and other user use information. The information obtained is used only for this purpose and is stored on the server as a pseudonym.

2.2 Your personal data we obtain from a third party

For now, we do not obtain your personal data from any third party. If certain services may require your personal data from a third party, we will notify you in advance and obtain your consent.

2.3 What permissions do we use to get your data

2.3.1. Changing your wifi and network status.

Changing your network status to create transfer connection.

2.3.2. Get your location (GPS and network-based)

Get your location to create transfer connection.

2.3.3. Read phone status and identity

We use this permission to create transfer connection.

2.3.4. Read, modify or delete the contents of your storage

We use this permission so that help you manage the files of your storage.

2.3.5. Draw over other apps

This permission allows the APUS File Manager to display a floating window on other apps so that we can show the new files notification.

2.3.6. Install shortcuts

This permission is used to install shortcuts on launchers, so users can continue using APUS File Manager related function.

2.3.7. Receive GCM notification

This permission allows users to receive GCM notification for subscription services.

2.3.8. Find accounts on the devices

This permission allows APUS to check if users have logged in Google Play and provide relative app installation service for users.

2.3.9. Run at startup

APUS File Manager will run at startup to provide users with services.

2.3.10. Prevent Phone from sleeping

The only purpose for using this permission is to prevent the phone from going to sleep when you are using capture.

2.3.11. SMS, contact and account information

Cookie is a small piece of text sent to a browser by a website visited by a user. It helps the browser to record user access information, such as preferred language and other settings. In this way, users will have an easier and more practical experience when they visit the same website the next time. Cookie plays a vital role. Without cookie, the user’s experience of Internet will be greatly reduced, and some website features or services may not even work properly. We use cookies to provide you with a complete web browsing service. We do not collect cookie information by ourselves. Please note that the websites you visit may use cookie to store your preferences, settings, login status, etc. For example, when you visit a webpage that has a login function for the first time, you need to enter a user name and password to log in. After logging in, the website will record your login status, When you switch different pages under the site, you do not need to re-enter the user name and password, you can directly browse the content of the web page. Websites may use cookie to recommend advertisements. For example, some websites use cookie to record websites that you click on to prevent you from seeing duplicate advertisements. We provide the ability to disable and delete cookies. You can disable or delete cookies.

To make it easier for you to open web pages, we provide web page caching. We allow websites you visit to store some web page data, such as web page pictures and other information. When you visit the site next time, the site will directly read the saved data for display, thereby to open the webpage faster. The cache will expire due to expiration or manual removal. We will not upload any cached content.

4. How We Share, Transfer and Disclose Your Personal Data

We will share with or transfer or disclose your personal data to a third party with your consent or explicit instructions. In addition, to improve the quality of our service, we may also share with or transfer or disclose your personal data to a third party under the following circumstances.

4.1. Subsidiary Products

We may share your personal data with our subsidiary products to provide a more consistent experience and better service. We guarantee that our subsidiary products will treat your personal data in accordance with the purposes and requirements shown in this Policy. We will obtain your prior consent again if our subsidiary products wish to use your personal data for purposes other than those set forth in this Policy.

4.2. Affiliated Company

We may share your personal data with our affiliated companies and will ensure their processing of your personal data is in compliance with the purposes and requirements of this Policy. We will obtain your prior consent again if affiliated companies intend to use your personal data for other purposes than set forth in this Policy.

4.3. Third party service provider

We may engage third party service providers to provide specific services. Third party service providers may collect data when providing services and we will ensure that they follow our instructions, follow the purposes and requirements set out in this policy to process your personal data, and take appropriate confidentiality and security measures to safeguard data security.

4.3.1. Search Function

In order to provide you with comprehensive search results, we provide you with a variety of different search engines for your choice. The search engines we use include: Google, Bing, Yahoo, Aol, Ask, Baidu, Sogou, DuckDuckGo, Yandex, Naver, Daum and their corresponding contracting agencies. You can choose your favorite search engine. When you search, we will use your search keywords, go to the search engine server you selected or its corresponding contracting agency server, and finally display the query results to you.

4.3.2. Search Suggestions

In order to help you quickly find the content you want to search for, and provide more accurate search results, when you enter keywords, we recommend some search terms that you may need based on your input. In this process, we go to the third-party search suggestion server according to the keywords you entered. The third-party search suggestion servers include: Google, Bing, Yahoo, Aol, Ask, Baidu, Yandex, Naver, and Affinity, etc. After querying the results, the results will be displayed to you. You can directly select the search terms you want to search for. In the process, we will not collect any of your personal data.

4.3.3 Visiting a Web Page

In order to realize the function of browsing the webpage, we will request the content of the webpage according to the webpage link address you provided, and then display the content of the webpage returned by the server. In this process, website may collect your relevant data,such as user agent, cookies, browsing track and so on. In addition, to implement special functions in certain web pages, the website may use the browser to apply for the location of your address or mobile phone file information, for example: pictures that need to be uploaded to the avatar, and microphone information. After you authorize it, the website can display related functions.

4.3.4. Statistics

In order to analyze data and provide you with better services, we use the services of Apps Flyer. The service needs to obtain your information including: application package name, application version, application installation time, system version, Android ID, country information, mobile phone language information, mobile phone brand, mobile phone model. The information obtained is only used for this purpose.

4.3.5. Attribution of installation channel

In order to attribution of installation channel and provide you with better services, we use the services of a third party service provider. The service needs to obtain your information including: application package name, application version, application installation time and other applications Information; , system version, Android ID, country code , information, mobile phone language, system version and other system information; power, charging type, sensor information, mobile phone brand, mobile phone Type, network information, CPU information and other device information.model. The information obtained is only used for this purpose.

4.4 Share of your personal data as required by law

Subject to compliance with this Policy, we may be required to share or disclose your personal data under certain circumstances, such as in accordance with laws and regulations, and compulsory requirements of government orders; to safeguard the legitimate rights and interests of yours, ours, and third parties; and to prevent or deal with fraud, secure or technical problems.

4.5 Change of organization and existing status of our company

For any change of the organization or existing status of our company (such as restructuring, merger or bankruptcy), your personal data may be transferred to the company entity after change or our affiliated company (the “Data Transferee”). The Data Transferee will continue to be bounded by this Policy.

5. Process Your Personal Data Using Third Party Services

The Product may contain a hyperlink directing to third party products or services, such as a hyperlink to another website. You may click the hyperlinks in this Product to access third party products or services. Meanwhile, we may also embed third party links in this Product and you may click these links to access or use third party products or services on the interface of this Product. We hereby remind you that when you access or use third party products or services via the above methods whereby your personal data will be obtained by such third party products or services, the privacy policies of such third party products or services will apply to such personal data.

6. How We Store and Protect Your Personal Data

6.1. Security protection of personal data

We are committed to protecting your personal data. We have adopted all possible security technologies and procedures to protect your personal data against unauthorized access, use, revision, damage, destruction or disclosure. These security measures mainly include the following:

6.2. Personal data storage term

We will store your personal data for the necessary period for data collection and processing purposes. Beyond the above-mentioned period, we will delete or anonymize personal data.

Junk file scan results, new file data, fast transmission history, web page transmission history, etc. These data are all stored locally and are available throughout the application lifecycle. You can manually clear this data at any time.

The access records, application execution logs, and application debug logs of the cloud service are stored on the server for a short period of time, typically 7 days. If this period expires, we will delete or anonymize the data.

Application usage data is pseudo-persistently stored on the server for data analysis. You can access, edit or delete your data in the manner described in section.

After you cancel your account, we may not be able to delete your personal data immediately due to technical reasons; however, we will delete it during the next system update, and we undertake not to process your personal data during the period between cancellation of your account and the next system update.

7. How You Access and Control Your Personal Data

7.1. Access and revise your personal data

You may access and edit your personal data online through APUS User Information Center.

7.2. Change of your authorization scope

You may select on the page of APUS User Information Center to change your authorization scope for us to process your personal data. Please be minded that since all functions of the Product need certain basic personal data for normal operation, certain functions of the Product may not operate normally when you withdraw your consent to processing of some personal data.

When we receive your withdrawal of consent, we will no longer process your corresponding personal data.

7.3. Rejection of personalized advertising

You may always choose whether to receive promotional emails, messages, calls, and mails from us or third parties. You may also choose to no longer receive personalized advertisements through APUS User Information Center.

We will no longer use your personal data for the above-mentioned commercial promotion purposes when you refuse to receive interest-based advertisements.

Non-personalized ads don’t use mobile ad identifiers for ad targeting, they do still use mobile ad identifiers for frequency capping, aggregated ad reporting, and to combat fraud and abuse.

7.4. Delete your personal data

You may submit a request to us to delete your personal data when:

We may not be able to delete your personal data immediately due to technical reasons. We will delete it during the next system update. We will not process your personal data in any way during the period between your request of deleting your personal data and the next system update.

7.5. Respond to your requests

We may first verify your identity upon receipt of your request, and may request you to provide the necessary information for authentication.

We will respond to your request on the 30th day after we receive your request and contact with you in an appropriate way. If necessary, we may extend it (by an additional 30-day at most), and will inform you of the reason for the extension of the deadline on the 30th day after receiving your request. If we have reasonable reasons to believe that no measures are needed to respond your request, we will inform you of our decision 30 days from the date of receiving your request and provide you with appropriate explanation.

We will use best efforts to help you resolve relevant problems. If you are not satisfied with the response you received, you may refer the complaint to the relevant regulatory authority, or file a lawsuit before a competent judicial authority.

8. How We Process the Minor’s Data

This Product is not intended for a minor under 16 years old (or equivalent minimum age set by the laws of EU members). We will only process the information of these minors to the extent permitted by law and with the consent of their guardians.

We will implement relevant technical measures and make our best efforts to verify whether the processing of minors’ information has been approved by their guardians. We will try to delete relevant data as soon as possible if we are aware that we have collected the personal data of a minor without the prior consent of their certified guardians.

9. Contact Us

If you have any questions or suggestions about this policy, or you need to do your data management power to manage your privacy data, please feel free to contact us: filemanager-privacy@apusapps.com .
If you find any violation of this policy, please feel free to contact our DPO: dpo@apusapps.com.

10. Update of Privacy Policy

We reserve the right to revise or modify this Policy. For any update of this Policy, we will send you notice on the interface of this Product to remind you of relevant updates and indicate the updated provisions for your ease of reading. Please make sure that you completely read and fully understand the updated Privacy Policy. By continuing to use this Product, you will be deemed to have accepted the updated version of this Policy. We will not reduce your rights under this Policy without your explicit consent.

11. How Your Personal Data Is Transferred Globally

We provide APUS products and services around the world, which means to conduct business globally, your personal data might be transmitted to a jurisdiction or accessed from such jurisdiction outside of the country/region where you use this Product. These jurisdictions include but are not limited to Singapore, United States, and China.

Please note that we only return demographic information to China and we do not include information on individual user identities. At the same time, in order to provide you with better services, our third party partners may transmit your data to other countries. For example, in order to detect robots or cheating, we have purchased a Chinese supplier’s traffic monitoring service. The merchant may return the user information to China in order to assist us in analyzing whether there is cheating in the user.

Personal data protection legislation in such jurisdiction might be different or even absent. Under such circumstance, we will adopt various measures to ensure security of your personal data. For instance, we will ask you for your explicit consent before transmission of your personal data, or implement security measures such as encryption and pseudonymisation during data transmission; when your personal data is transferred to such jurisdictions, we will apply the same protection of your personal data in accordance with the Policy. We will endeavor to protect your personal data with the measures stipulated in Article 46 and Article 47 of the EU General Data Protection Regulation.

The content of this Privacy Policy shall be adjusted according to the local legal or statutory requirements.

Last updated: [2018/5/25]