CommLink Privacy Policy

Please read this policy carefully. Thank you for your understanding and support.

Updated Date: December 12, 2025 | Effective Date: December 12, 2025

I. Introduction

Welcome to use CommLink (hereinafter referred to as "we"). We fully understand the importance of personal information and shall strictly comply with the Personal Information Protection Law of the People's Republic of China, the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) and other valid data protection and privacy laws, regulations and industry norms in force in other countries/regions. We adopt strong encryption technology to protect your privacy and security, and formulate strict management systems to regulate all data processing activities. When you access or use the relevant services of CommLink, it means that you agree to the provisions of this policy on how we collect, use, store, transmit and protect your personal information (including sensitive personal information: facial information). If you disagree with any content of this Privacy Policy, please immediately stop using or accessing our products and services.

If you are under the age of 14, you may only use our services or provide information to us after reading this policy accompanied by a legal guardian and obtaining the explicit consent of the legal guardian.

Key points of this Privacy Policy are as follows:

For more detailed information, please read the corresponding chapters according to the following index:

1. Personal Information We Collect
2. How We Use Your Information
3. How We Use Cookies and Similar Technologies
4. Description of Mobile System Permission Application and Usage
5. Data Collection and Storage
6. Your Rights and Exercise Methods
7. How We Protect Your Personal Information
8. How We Process Personal Information Provided by Minors
9. How We Share, Transfer and Publicly Disclose Your Personal Information
10. Supplementary Explanation on Cross-border Transmission of Information
11. Description of FCM Push Service and Information Sharing Rules
12. Updates to This Policy
13. Scope of Application
14. How to Contact Us

II. Personal Information We Collect

When providing services, we will collect, store and use the following corresponding information according to the functional scenarios you use, and all information collection shall follow the principle of "minimum necessity":

Functional Scenarios Types of Collected Information Purposes of Collection Authorization Method
Account Registration/Login Mobile phone number/email address, verification code, username, password Identity verification, account management, cross-border service adaptation Explicit consent during registration
Real-name Authentication (Property/Administrator) Name, work certificate-related information (non-sensitive information) Compliant operation, access control of community equipment management permissions Separate pop-up authorization
Device Binding via QR Code Scanning Camera permission, device identification code, binding time Complete the association between device and account, realize device management functions Dynamic authorization of system permissions (revocable)
Door Access via Facial Recognition Facial images/feature information (sensitive personal information), facial verification records Realize identity verification for community access control and security admission management Separate pop-up for explicit consent (authorization can be withdrawn through APP settings)
Call and Message Push Device call records, message reception status, mobile phone notification permission Realize two-way calls between devices and users, and push service messages in a timely manner Default authorization when using the service (revocable through system settings)
Person/Owner/Device Management Basic owner information (name, housing number), device model/serial number, device operation status data Complete community personnel filing, device control and monitoring Voluntarily submitted and agreed to use by you
Record Management Device call records, operation logs, fault feedback records, facial usage records Service traceability, troubleshooting, function optimization Automatically collected during service use (personal related records can be deleted in the APP)
Core Service Operation Device information (model, operating system, IMEI/IDFA), IP address, usage region Ensure the stability of cross-border services and adapt to network environments in different regions Default authorization when using the service (non-essential collection can be turned off through APP settings)

Supplementary explanation: We will store and process the shared information you provide to other parties through our services, as well as the information you submit, send or receive when using the services, as necessary according to the requirements of relevant functions to ensure the normal operation of the services.

III. How We Use Your Information

The purpose of collecting personal information is to provide you with products or services and comply with applicable laws, regulations and other normative documents. We will use the collected information for the following purposes:

Special Commitments:

According to relevant laws, regulations and internationally accepted rules, we are not required to obtain your authorization and consent for collecting and using your personal information in the following circumstances:

Please understand that our functions and services will be continuously updated and developed. If a new function or service needs to collect your information which is not covered in the above description, we will separately inform you of the content, scope and purpose of information collection through page prompts, interactive processes, APP announcements and other ways, and collect such information only after obtaining your consent.

IV. How We Use Cookies and Similar Technologies

A Cookie is a small file containing a string of characters that is sent to your device when you access the relevant services. When you use the services again, the Cookie enables the system to identify your device and usage preferences. You may reset or reject all Cookies through your device browser or system settings, or set a prompt when Cookies are sent, but some service functions may not work properly as a result.

When you use the relevant services of CommLink, we will use Cookies, anonymous identifiers and other similar technologies to collect and store your access and usage information. We regard the information collected through such technologies as non-personal information, but if the local law regards IP address or similar identification marks as personal information, we will protect such information in accordance with the relevant provisions on personal information. We mainly use Cookies and similar technologies to achieve the following functions:

V. Description of Mobile System Permission Application and Usage

To provide you with more complete services related to CommLink, we will apply to your mobile phone for the corresponding system permissions according to the specific functions you use. We promise that all permission applications are necessary for realizing the corresponding services without any redundant permission applications, and we will apply for authorization from you in a friendly and clear manner. You may turn off the relevant permissions in the mobile phone system settings at any time. Turning off the permissions will only affect the use of the corresponding functions and will not affect other services. The relevant permission applications and usage instructions are as follows, all of which are standard statements for compliance review:

All permissions are optional authorization. You may choose whether to enable them according to your own needs. We will not discriminate against or refuse to provide you with basic services because you refuse to grant non-core permissions. All permission invocations follow the principle of "authorization upon invocation and release after use", without any background silent invocation behavior.

VI. Data Collection and Storage

(I) Principles and Specifications for Data Collection

We always abide by the principles of "legality, legitimacy, necessity and good faith" and the principle of "minimum necessity" as required by the Personal Information Protection Law and data compliance requirements of various regions around the world to carry out data collection work. All data collection behaviors are centered on providing you with the core services and related auxiliary functions of CommLink without any meaningless information collection. The specific collection specifications are as follows:

(II) Core Rules for Data Storage

We securely store all your personal data and usage behavior-related data. The storage behavior strictly complies with the requirements of laws and regulations and industry safety standards, providing comprehensive security protection for your stored data. The core storage rules are as follows:

(III) Supplementary Explanation on Data Storage

1. We will not store your personal data in any unknown storage nodes other than overseas servers. For relevant information on cross-border storage, please refer to the subsequent chapters of this policy. All cross-border storage behaviors have obtained your explicit consent and comply with local regulatory requirements;

2. If it is necessary to extend the data storage period due to legal and regulatory requirements (such as cooperating with judicial investigations and retaining transaction records), we will complete the data deletion or anonymization processing immediately after the expiration of the compliance period;

3. You may apply to inquire about the storage status, storage location and storage period of your personal data at any time through the methods listed in this policy, and we will provide you with the relevant inquiry results within the specified time limit.

VII. Your Rights and Exercise Methods

In accordance with the Personal Information Protection Law of the People's Republic of China, the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) and other relevant laws and regulations of various regions around the world, you are entitled to the following rights, and we provide you with convenient channels for exercising such rights:

Warm reminder: You shall ensure that the personal information provided by you is true, legal, valid and complete, and update and maintain it in a timely manner. You shall bear the responsibility for any service abnormality or damage to rights and interests caused by untrue or incomplete information.

VIII. How We Protect Your Personal Information

We are committed to providing comprehensive protection for the security of your personal information, and adopt various measures such as technical protection, institutional control and security system construction to prevent risks such as information leakage, loss, improper use, unauthorized access and disclosure, so as to ensure that your personal information is at a reasonable security level:

Please understand that although we have taken the above reasonable and effective measures, due to technical limitations and possible malicious means, the Internet industry cannot guarantee 100% information security. The system and communication network you use to access the services may have problems due to factors beyond our control. Therefore, we strongly recommend that you take active measures to protect the security of your personal information, including but not limited to setting complex passwords, changing passwords regularly, not disclosing account passwords and verification codes to others, and logging out in a timely manner after using public terminals. If you find abnormal account login or security vulnerabilities, you shall immediately notify us.

Your assistance will help us better protect the security of your personal information.

IX. How We Process Personal Information Provided by Minors

We strictly abide by the relevant laws and regulations of various regions around the world on the protection of minors' information, regard anyone under the age of 14 as a minor, and attach great importance to the protection of minors' information.

X. How We Share, Transfer and Publicly Disclose Your Personal Information

(I) Sharing

We will not sell any personal information to third parties. If it is really necessary to share your personal information, it is only for legitimate, legal, necessary, specific and clear purposes, and we strictly abide by the following requirements:

(II) Transfer

Except for the following circumstances, we will not transfer your personal information to any subject:

(III) Public Disclosure

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

XI. Supplementary Explanation on Cross-border Transmission of Information

(I) Storage Location

Your personal information (including facial information) will be mainly stored on servers in mainland China. To provide cross-border services, some data will be transmitted to compliant servers in [specific cross-border storage regions, e.g., Singapore, Ireland of the EU]. The transmission process strictly complies with the Personal Information Protection Law of the People's Republic of China and the data protection laws and regulations of various regions around the world (such as the cross-border data transmission requirements of GDPR and the cross-border data flow compliance rules of various countries/regions), and we will separately inform you of the purpose of data outbound and the recipient through in-site messages or emails and obtain your authorized consent.

(II) Supplementary Explanation on Storage Period

The cross-border stored data shall simultaneously implement the storage period rules listed in the chapter of "Data Collection and Storage" of this policy. After account cancellation or service termination, all personal data stored overseas will be completely deleted or anonymized synchronously with the domestic data without any delayed retention behavior.

In the event of the suspension of operation of our products or services, we will inform you in advance in the form of APP push notifications, announcements, etc., and delete your personal information within a reasonable time limit or explain the transfer method of the information to you.

XII. Description of FCM Push Service and Information Sharing Rules

To ensure that you can receive the service notifications of CommLink in a timely manner (such as device call reminders, account security notifications, function update prompts, etc.), we currently only use Google Firebase Cloud Messaging (FCM) push service. The FCM service is provided by Google LLC, and its information processing behavior complies with Google's Privacy Policy and relevant service terms.

The information we collect through the FCM service only includes: device identifiers (e.g., IMEI, Android ID), network type and device operating system version. The above information is only used to adapt to the push needs of different devices and ensure the stability of the push service, and will not be associated with your personal identity information. We will require Google to strictly abide by the data confidentiality and security requirements.

Supplementary explanation on information sharing:

For your convenient access and enriched experience, CommLink may contain links to products or services provided by third parties (such as third-party SDKs, cooperative service entrances, etc.). You may choose whether to access such content or use third-party services. We have no control over the products or services provided by third parties and cannot interfere with their information processing behaviors.

The information generated during your use of third-party products or services is independently collected and processed by third parties, and the relevant risks are borne by third parties. Such information processing behaviors are not applicable to this policy. We recommend that you carefully read their privacy policies and service terms before using third-party services to protect your legitimate rights and interests.

Warm reminder: If there are links to products or services provided by third parties in CommLink (such as cooperative service entrances), you may independently choose whether to access or use them. We have no control over third-party services, and their information processing behaviors are regulated by their own privacy policies. The relevant risks are borne by third parties. We recommend that you carefully read their privacy policies and service terms before use.

XIII. Updates to This Policy

We may modify and update this Privacy Policy irregularly according to changes in the laws and regulations of various regions around the world (such as adjustments to cross-border data protection policies, updates to facial information protection-related laws and regulations, changes in privacy compliance requirements of different countries/regions) or business adjustments:

XIV. Scope of Application

XV. How to Contact Us

If you have any questions, opinions or suggestions about the content of this policy, or need to exercise the rights related to personal information and file complaints and reports, you may contact us through the following ways:

1. Customer Service Email: app@uniwin-global.com

2. Business Cooperation Email: violet.liu@uniwin-global.com

3. Business Cooperation Phone: +86 15820426972

4. Overseas Service Consultation: rana@uniwin-global.com

5. Address: Room 388, Building A7, Yintian Industrial Zone, Building A, Yongqi Business Building, Yantian Community, Xixiang Street, Bao'an District, Shenzhen City

Under normal circumstances, we will reply to your consultation or process your application within 15 working days; if you are not satisfied with the reply result, you may further file a complaint with the relevant regulatory authorities of the country/region where you are located.

All users around the world are entitled to the following rights and protections: