GrowthPal Privacy Policy

Last Updated and Effective: January 8, 2026

Introduction
We understand the importance of your personal information and are committed to protecting it. We strive to maintain your trust and adhere to the following principles in protecting your personal information: accountability, purpose specification, consent, data minimization, security, participation, and transparency. We also commit to adopting industry-standard security measures to protect your personal information.

Please read and understand this Privacy Policy before using our products or services. It will help you understand how we collect, use, store and share your information when you use our related services (including but not limited to online information, interaction, cloud backup and collaboration sync, collectively the "Services"), and how we provide access, update, control and protection of such information. Important provisions regarding your rights in personal information are highlighted in bold for your attention.

If you do not agree with any part of this Privacy Policy, you may choose to stop using our services. By using or continuing to use our services, you agree to our collection, use, storage and sharing of your relevant information in accordance with this Privacy Policy. If you have any questions about this Privacy Policy or related matters, please contact us at chuangxiaoweilai@gmail.com.

Developer Information

Company Name: Beijing Chuangxiaoweilai Technology Co., Ltd.
Website: https://www.chuangxiaoweilai.com/

Integrated SDK List

* Umeng SDK

Third Party: Umeng Tongxin (Beijing) Technology Co., Ltd., Beijing Ruixun Lingtong Technology Co., Ltd.

Function: Multi-platform sharing to help users share content

Types of Personal Information Collected: Device identifiers (IMEI, Android ID, IMSI, BSSID, SSID, MCC and MNC, device serial number, SIM serial number), device network information (MAC address, RSSI), location, storage, app list

* Pangle/ByteDance SDK

Third Party: Beijing Juliang Engine Network Technology Co., Ltd.

Function: Ad delivery and attribution, anti-fraud

Types of Personal Information Collected: Device brand, model, OS version, resolution, network signal strength, IP address, device language, sensor information (e.g., gravity, acceleration, orientation, gyroscope, pressure, linear acceleration), location, device identifiers (e.g., IMEI, OAID, IMSI, ICCID, GAID (GMS only), DHCP, app run list, carrier, android_id, SIM status, BSSID, MAC address, device serial number, app install list)

* Beizi SDK

Third Party: Shanghai Beizi Network Technology Co., Ltd.

Function: Commercial performance ad delivery

Types of Personal Information Collected: Device brand, model, timezone, language, system version, network type, UserAgent, screen size, orientation, DPI, system update time, boot time, disk space, physical memory, carrier, sensor information (e.g., gravity, acceleration, orientation, gyroscope, pressure, linear acceleration), gesture content, CPU, OAID, app name, app version, package name, run state, product interaction data, ad data (impression, click, conversion), crash data, performance data, app install list

Auto-start or Associated Start Notice:

Widget:

This app supports home screen widgets. The widget feature needs to listen for the system broadcast (android.appwidget.action.APPWIDGET_UPDATE), which is used by the system to refresh widgets. If you use the app's home screen widget feature, the app must use auto-start capability to wake widget-related services (including but not limited to widget data updates) by receiving the system broadcast.

I. Information We May Collect and How We Collect It

When we provide services, we may collect, store and use the following information relating to you. If you do not provide relevant information, you may not be able to enjoy certain services or achieve the intended effect of such services.

(1) Information You Provide to Us

1. Information you share with others through our services and information you store when using our services.

2. Cloud Backup and Collaboration: When you use cloud backup (including automatic and manual cloud backup) or enable Family Collaboration, we will collect and store data changes and version history recorded in the app.

(2) Information We Obtain About You

When you use our services we may collect the following information:
1. Log information refers to technical information that may be automatically collected through cookies or similar technologies when you use our services, including:

(1) Device or software information, such as configuration information provided by your mobile device, web browser or other programs used to access our services, your IP address and the version and device identifier of your mobile device;
(2) Information searched or browsed when using our services, such as search terms, URLs of social media pages visited, and other information and content you browse or request;
(3) Information about mobile apps and other software you have used, and your use of such apps and software;
(4) Information about your communications through our services, such as accounts communicated with and the time, data and duration of communications;
(5) Information (metadata) contained in content you share through our services, such as the date, time or location of shared photos or videos.
2. Location information: When you enable device location and use our location-based services, we may receive URLs of source and destination websites. We may also obtain information relating to your IP address, proxy server, operating system, browser and add-ons, device identifier and/or ISP or mobile carrier. If you use our "Services" on a mobile device, the device may send us your location data based on your device settings. We will ask for your permission before using GPS or other tools to determine your precise location. Information we collect about your location includes:

(1) Your geographic location collected via GPS or WiFi when you use our services on a location-enabled mobile device;
(2) Real-time information about your location provided by you or other users, such as your region in your account information, shared information showing your current or past location, or geotag information in shared photos;
(3) You may stop collection of your location information by turning off location.
3. When you use the camera or video function to set an avatar or upload images or video files, we will request access to your camera and photo library, which is necessary for these features.
The above services may require you to authorize us to access location (GPS), camera, photo library and microphone in your device settings. You may enable or disable these permissions at any time in your phone or device settings. Enabling a permission means you authorize us to collect and use the relevant personal information for the corresponding function; disabling means you revoke that authorization, and we will no longer collect or use such information or provide the corresponding function. Disabling a permission does not affect our prior processing of your information based on your authorization.
Please note: Information we collect in the course of providing services that can identify a user, alone or in combination with other information, will be treated and protected as your personal information under this Privacy Policy while so combined; information that cannot identify you alone or in combination with other information is not personal information in the legal sense.

(3) How We Collect Information

We may collect and use your information through cookies and similar technologies and store it as log information for the following purposes:

1. To remember your identity. For example, cookies help us recognize you as our user or save preferences or other information you provide;
2. To analyze your use of our services. For example, we may use cookies and similar technologies to understand what activities you perform using our services or which pages or services are most popular.
(4) If we decide to cease operation of a service, we will stop collecting your personal information after the relevant service ceases. We will notify you of the cessation by announcement. We will delete or anonymize personal information we hold unless otherwise required by law. Where children's personal information is involved, we will notify guardians in a timely manner.

II. How We May Use Your Information

We may use the information collected in the course of providing services to you for the following purposes:

  1. To provide you with the services you use and to maintain and improve such services;
  2. For identity verification, customer service, security, fraud detection, archiving and backup when we provide services, to ensure the security of our products and services;
  3. For location information for local channels. If you refuse our local channel location service, you may turn it off or cancel in [Profile] - [More Settings]. Doing so will prevent you from using that service but will not affect other services;
  4. To help us design new services and improve existing services;
  5. Software authentication or software upgrade management;
  6. To allow you to participate in surveys about our products and services;
  7. To enable cloud data sync and recovery. For example: after enabling Family Collaboration or automatic backup, automatically sync the latest cloud data to this device, or support your manual restore to a previous version.

III. Cloud Backup and Family Collaboration

1. Family Collaboration: When enabled, data changes are automatically synced to the cloud. Cross-device automatic restore within the family account is supported (current device data will be replaced by the cloud version); data is shared within the family.
2. Automatic Cloud Backup: Data is backed up automatically when it changes. Cross-device automatic restore under the same account is supported; data is shared under the same account.
3. Cloud Backup: Triggered manually by the user. Manual restore only; data is shared under the same account.
4. Control: You may independently turn "Automatic Backup" and "Automatic Restore" on or off in the relevant settings.
5. Automatic sync: After each app restart, user login, or viewing user info, the latest cloud data will be synced to this device; you may also manually trigger restore in Family Collaboration settings. After automatic restore, you may roll back to a previous version (via [Profile] → [Backup & Restore]).

IV. Information We May Share

Except in the following circumstances, we will not share or transfer your personal information to third parties without your consent, or the shared or transferred information will be anonymized or de-identified so that the recipient cannot re-identify natural persons:

(1) To perform our obligations under this Privacy Policy and protect our legitimate rights and interests, or where reasonably necessary to comply with applicable laws, protect the public interest, or protect the personal or property safety or legitimate rights of us, our affiliates, our customers, other users or employees;
(2) As required by law or by administrative or judicial authorities;
(3) Where you violate applicable Chinese law, or breach an agreement you have entered into with us (including electronic agreements signed online) or our platform rules, and disclosure to a third party is required;
(4) Sharing within the family: When you use "Family Collaboration," your data will be shared and synced within the family account members you authorize.
(5) As our business continues, we and our affiliates may conduct mergers, acquisitions, asset transfers or similar transactions, and your personal information may be transferred as part of such transactions. We will notify you before any transfer and protect your rights in accordance with applicable law.
V. Data Sharing and Disclosure
Except in the following circumstances, we will not share your personal information with any other third party.

(1) Sharing with your explicit consent or authorization or when you actively choose to share.

(2) Sharing as required by law. We may share your personal information where required by law, for litigation or dispute resolution, or at the request of administrative or judicial authorities.

(3) Sharing with third-party service providers. You authorize and agree that we may engage third-party service providers to provide certain services or perform functions on our behalf. We will share your information only for the lawful, legitimate, necessary, specific and clear purposes stated in this policy. We will assess the data security capability and sharing risk of third-party service providers before sharing and require by agreement that they access only the information necessary to perform their functions; we will not use your personal information for any other purpose. If they use your personal information beyond the sharing purpose, we will require them to obtain your separate consent.

For purposes such as push, share, screen casting, login, anti-malware and anti-fraud, and to improve service security and operational quality and efficiency, our products may integrate third-party SDKs or similar applications that may collect your location, device information (including Android ID, MAC address, IMEI, IDFA, OAID, IMSI), phone number, app list, carrier information, network information, service log information, etc.

Rest assured that except with your explicit consent, we will not share personal information that can contact or identify you with authorized partners. We will de-identify personal information that can identify you so that authorized partners cannot identify you.

VI. How We Protect Your Information Security

(1) We use industry-standard security measures to protect the personal information you provide from unauthorized access, disclosure, use, modification, damage or loss. We will take all reasonably practicable measures to protect your personal information.

(2) We will take all reasonably practicable measures to ensure we do not collect unnecessary personal information. We will retain your personal information only for as long as necessary to achieve the purposes stated in this policy, unless a longer retention period is required or permitted by law.

(3) We use various security technologies and procedures to prevent loss, misuse, unauthorized access or disclosure of information. For example, in certain services we use encryption (e.g., SSL) to protect the personal information you provide.

(4) Although we have taken reasonable and effective measures and complied with relevant legal standards, please understand that due to technical limitations and possible malicious means, in the Internet industry we cannot guarantee that information will always be 100% secure. You should be aware that the systems and communications networks you use to access our services may encounter issues due to factors beyond our control.

(5) Cloud Backup Special Notice and Disclaimer:
1. To avoid data conflict, please avoid recording on multiple devices at the same time where possible.
2. If data conflict or erroneous overwriting occurs, you may manually restore to a previous version via [Profile] → [Backup & Restore] → [Automatic Backup].
3. Cloud backup will strive to ensure data integrity and consistency but does not guarantee absolute security. We recommend that you periodically backup and export important data to prevent data loss.

VII. Information You Share

(1) Your personal information is an important part of the services we provide to you. We will keep your information confidential as required by law, but we may publicly share relevant information about you with all users of the service, for example comments or questions you post (including your account nickname and avatar), your responses to others' posts, and location data and log information related to such content. Other users of our services may also share information about you (including location and log information). As long as you do not delete this information, it will remain in the shared area; even after you delete it, it may be independently cached, copied or stored by other users or unaffiliated third parties we do not control, or saved by them in other areas.

Therefore, please consider carefully the content you upload, publish and share through our services. In some cases, you may control who can view your shared information through the privacy settings of certain services. To request deletion of your relevant information from our services, please do so through the means provided in the relevant service terms.

(2) Certain personal information may be considered sensitive due to its nature, such as your race, religion, health and medical information. Sensitive personal information is subject to stricter protection than other personal information.

Please note that content and information you provide, upload or publish when using our services (e.g., photos of your social activities) may reveal your sensitive personal information. You should consider carefully whether to disclose such sensitive personal information when using our services.

VIII. Your Rights

In accordance with relevant Chinese laws, regulations and standards, as well as common practice in other countries and regions, we safeguard the following rights you have over your personal information:

(1) Access Your Personal Information

You have the right to access your personal information, except where otherwise provided by law. To exercise your right of access, you may do so by: viewing in [Profile] - [Account Settings].

(2) Correct Your Personal Information

When you find that we have processed your personal information incorrectly, you have the right to correct it. You may apply for correction through the means set out in "(1) Access Your Personal Information."

(3) Delete Your Personal Information

You may request us to delete your personal information in the following circumstances:

1. If our processing of personal information violates laws or regulations;

2. If we collected or used your personal information without your consent;

3. If our processing of personal information breached our agreement with you;

4. If we no longer provide you with products or services.

If we decide to respond to your deletion request, we will also notify entities that have obtained your personal information from us and require them to delete it in a timely manner, unless otherwise required by law or such entities have your separate authorization. After you delete information from our services, we may not immediately delete the corresponding information from the backup system, but will delete it when the backup is updated.

(4) Change the Scope of Your Consent

Each business function requires some basic personal information to be completed. For collection and use of additional personal information, we will notify you by pop-up to obtain your consent.

If you do not agree, we will no longer process the corresponding personal information. Your disagreement will not affect our prior processing of personal information based on your consent.

(5) Responding to Your Above Requests

For security purposes, you may need to provide a written request or otherwise prove your identity. We may require you to verify your identity before processing your request.

We will respond within thirty days. If you are not satisfied, you may contact us at chuangxiaoweilai@gmail.com.

We generally do not charge for reasonable requests, but we may charge a reasonable cost for repeated or excessive requests. We may refuse requests that are repetitive, require excessive technical means (e.g., developing new systems or fundamentally changing current practice), pose risks to the legitimate rights of others, or are highly impractical (e.g., involving information on backup tapes).

We will be unable to respond to your request in the following circumstances:

1. Related to the personal information controller's performance of legal obligations;

2. Directly related to national security or defense security;

3. Directly related to public security, public health or major public interests;

4. Directly related to criminal investigation, prosecution, trial and execution of judgments;

5. The personal information controller has sufficient evidence that the data subject has acted in bad faith or abused rights;

6. Where necessary to protect the life, property or other major legitimate rights of the data subject or other individuals but it is difficult to obtain consent;

7. Where responding to the data subject's request would seriously harm the legitimate rights of the data subject or other individuals or organizations;

8. Involving trade secrets.

IX. Global Transfer of Your Personal Information

In principle, personal information we collect and generate within the People's Republic of China will be stored within the People's Republic of China.

As we provide products or services through resources and servers around the world, your personal information may, with your consent, be transferred to jurisdictions outside the country or region where you use our products or services, or be accessed from such jurisdictions.

Such jurisdictions may have different data protection laws or none. In such cases, we will ensure that your personal information receives protection equivalent to that within the People's Republic of China. For example, we may seek your consent for cross-border transfer of personal information, or implement de-identification or other security measures before cross-border transfer.

X. Minors

If you are a minor under 18 years of age, you should read and agree to this Privacy Policy together with your parents or guardians before using our related services.

We protect the personal information of minors in accordance with relevant national laws and regulations, and will collect, use, store, share, transfer or disclose minors' personal information only where permitted by law, with the explicit consent of parents or guardians, or where necessary to protect minors.

XI. Scope and Exceptions of This Privacy Policy

(1) Except for certain specific services, all our services are subject to this Privacy Policy. Those specific services will be subject to their own privacy policies. The privacy policy for a specific service will describe in more detail how we use your information in that service. That policy forms part of this Privacy Policy. Where a specific service's privacy policy is inconsistent with this Privacy Policy, the specific service's privacy policy shall apply.

(2) Our services may include or link to social media or other services (including websites) provided by third parties. Such services may be operated by the third party or by us. Your use of such third-party services (including personal information you provide to them) is subject to that third party's terms of service and privacy policy, which you should read carefully.

This Privacy Policy applies only to information we collect and does not apply to services provided by third parties or third parties' information use practices. We are not responsible for any third party's use of information you provide, whether you access, browse or use such software or websites through our links or guidance.

XII. Amendment and Notice of This Privacy Policy

To provide you with better service, we may issue updated versions and remind you of relevant updates. We may amend the terms of this Privacy Policy from time to time, and such amendments form part of this Privacy Policy.

We will not reduce your rights under this policy without your explicit consent. We will publish any changes to this policy on this page. For material changes, we will also provide notice in a prominent place on our homepage or by other means before the amendment takes effect. In that case, you may choose to stop using our services; if you continue to use our services, you agree to be bound by the revised Privacy Policy. Material changes include but are not limited to:

(1) Major changes in our service model, e.g., the purpose of processing personal information, the types of personal information processed, or the manner of use of personal information;

(2) Major changes in our ownership structure or organization, e.g., ownership changes due to business adjustment, bankruptcy or merger;

(3) Changes in the main recipients of personal information sharing, transfer or public disclosure;

(4) Major changes in your rights regarding personal information processing and how you may exercise them;

(5) Changes in the department responsible for personal information security, contact details or complaint channels.

XIII. How to Contact Us

If you have any questions, comments or suggestions about this personal information protection policy, please contact us at chuangxiaoweilai@126.com.

This agreement is concluded in Xicheng District, Beijing, People's Republic of China. The laws of the People's Republic of China (excluding Hong Kong, Macau and Taiwan for this purpose) shall apply to all disputes, claims or other matters arising from or in connection with the performance, interpretation or use of our platform or services under this agreement. Any dispute between you and us, our affiliates or our products or services shall be resolved through friendly negotiation; if negotiation fails, you agree to submit the dispute to a court with jurisdiction in the place where this agreement was concluded.

You confirm again that you have read and fully understood the above terms.