《Sanctuary of Whispers》 Privacy Policy

Updated: October 20, 2025

I. Introduction and Definitions

  1. Beijing Hesheng Yiming Information Technology Co., Ltd., hereinafter referred to as "the Company" or "we".

  2. Sanctuary of Whispers, hereinafter referred to as the "Application".

  3. User, that is, the user of this application (hereinafter referred to as "you")

This application was developed by our company. We strictly abide by laws and regulations to provide you with a safer and more reliable service. We also attach great importance to the privacy and personal information security of our users. We follow the industry's mature security and privacy standards and implement strict security measures to protect your personal information.

This policy will help you understand the following: We hope to use this Privacy Policy to clearly, accurately and completely explain to you how we collect, process and protect your personal information when you use this application.

II. How we collect and use your personal information

We will follow the principles of legitimacy, legality, and necessity to collect and use the personal information you provide during your use of our services or that is generated through your use of our products and/or services for the purposes described in this Policy. If we intend to use your personal information for other purposes not specified in this Policy, or use information already collected for a specific purpose for other purposes, we will inform you in a reasonable manner and obtain your consent again before use.

  1. Statistics To improve the product, this application integrates statistical functions. We need to collect the application's startup time, page visits and dwell time, device information (device brand and model, CPU type, screen parameters, operating system name and version, network type, operator information, IP address, User Agent information, device language, time zone, anonymous device identifier, whether the device is a simulator or has been rooted), application information (channel package, mini program scenario value, version number), and stack information when an error is reported.

  2. Exceptions to obtaining authorization and consent Please understand that according to laws, regulations and relevant national standards, we do not need to obtain your authorization and consent to collect and use your user information in the following circumstances:

III. How do we store personal information?

We attach great importance to information security and follow strict security standards. We use industry-standard security measures to protect the information you provide and adopt various reasonable technical, operational, and management security measures to protect the security of the information we collect. We prevent information from unauthorized access, public disclosure, use, modification, damage, or loss.

(1) Information Storage Location:
We store personal information collected and generated during operations within the People's Republic of China in accordance with laws and regulations. We will not transfer such information outside of the People's Republic of China.

(2) Storage Period:
We will only retain your information for as long as necessary to provide services to developers. After the storage period agreed upon with developers, we will regularly delete or anonymize your personal information, unless otherwise provided by laws and regulations.

IV. How we share, transfer, and publicly disclose your personal information

4.1 Sharing

We will not share your personal information with any other company, organization or individual, except in the following circumstances:

  1. Sharing with explicit consent: We will share your personal information with other parties after obtaining your explicit consent.

  2. We may share your personal information with external parties in accordance with laws and regulations, or at the mandatory requirements of government authorities.

  3. Sharing with our affiliates: Your personal information may be shared with our affiliates. We will only share necessary personal information for the purposes stated in this Privacy Policy. If an affiliate changes the purpose of processing your personal information, they will seek your authorization and consent again.

4.2 Transfer

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

  1. Transfer with explicit consent: We will transfer your personal information to other parties with your explicit consent;

  2. In the event of a merger, acquisition, or bankruptcy liquidation, if personal information is transferred, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy. Otherwise, we will require the company or organization to re-solicit your authorization and consent.

4.3 Public Disclosure

We will only disclose your personal information in the following circumstances:

  1. With your explicit consent;

  2. Disclosure based on law: We may disclose your personal information publicly when required by law, legal procedures, litigation or government authorities.

4.4 Exceptions to prior authorization and consent for sharing, transferring, and publicly disclosing information

Please understand that, in accordance with laws, regulations and relevant national standards, we do not need your authorization or consent to share, transfer or publicly disclose your personal information in the following circumstances:

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

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

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

  4. To protect your or other individuals' life, property and other major legal rights and interests, but it is difficult to obtain their consent;

  5. Information you disclose to the public on your own;

  6. Collected from legally disclosed information, such as legal news reports, government information disclosure and other channels.

V. How we protect your personal information

  1. We have implemented industry-standard security measures to protect the personal information you provide and prevent it from unauthorized access, public disclosure, use, modification, damage, or loss. We will take all reasonable and feasible measures to protect your personal information. For example, we encrypt data when exchanging it between the App and the Service; we also provide secure browsing via https for our website; we use encryption technology to ensure data confidentiality; we use trusted protection mechanisms to prevent malicious attacks on data; we deploy access control mechanisms to ensure that only authorized personnel can access your personal information; and we hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

  2. We have established dedicated management systems, processes, and organizations to ensure information security. For example, we strictly limit the personnel who have access to information, require these personnel to comply with their confidentiality obligations, and conduct audits.

  3. We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. We will only retain your personal information for the period necessary to achieve the purposes stated in this policy, unless an extension of the retention period is required or permitted by law.

  4. We will regularly update and disclose relevant content of reports such as security risks and personal information security impact assessments.

  5. The Internet is not 100% secure. We will do our best to ensure the security of any information you send us. Even if we make great efforts and take all reasonable and necessary measures, we may still not be able to prevent your user information from being illegally accessed, stolen, tampered with, or destroyed, which may harm your legitimate rights and interests. Please understand and voluntarily assume these risks of the information network.

  6. In the unfortunate event of a user information security incident, we will promptly inform you, in accordance with laws and regulations, of the following: the basic circumstances of the security incident and its potential impact, the measures we have taken or will take, suggestions for your own risk prevention and mitigation, and any remedial measures available to you. We will promptly notify you of the incident by email, letter, phone call, push notification, or other means. If it is difficult to inform each user individually, we will issue an announcement using reasonable and effective means. We will also proactively report the handling of personal information security incidents to regulatory authorities as required.

VI. How do we handle children’s personal information?

We attach great importance to the protection of children's personal information. Given the limitations of existing technology and business models, as well as the limited information we collect, it is difficult for us to proactively identify children's personal information. If you find that we have collected children's personal information without their knowledge or without the prior consent of a verifiable guardian, you can contact us in a timely manner. We will try to delete it promptly after discovery. If we discover the aforementioned situation ourselves, we will also delete it promptly, unless we are required by law to retain it.

VII. How to update this policy

Our Privacy Policy may change. Without your explicit consent, we will not reduce your rights under this Privacy Policy. We will post any changes to this Policy on this page.
For significant changes, we will also provide a more prominent notice. Significant changes to this Policy include, but are not limited to:

  1. Our service model undergoes significant changes, such as the purpose of processing personal information, the type of personal information processed, and how personal information is used;

  2. We have major changes in our ownership structure, organizational structure, etc., such as changes in ownership due to business adjustments, bankruptcy, mergers and acquisitions, etc.;

  3. Changes in the primary recipients of personal information sharing, transfer, or public disclosure;

  4. There are significant changes in your rights to participate in the processing of personal information and how to exercise them;

  5. When our responsible department for handling personal information security, contact information, and complaint channels change;

  6. When a personal information security impact assessment report indicates a high risk,
    we will also archive the old version of this policy for your review.

8. How to Contact Us

If you have any questions, comments or suggestions about this Privacy Policy, you can contact us in the following ways:

We will deal with your questions or suggestions as soon as possible. Generally, we will respond within fifteen working days.