Effective Date: [2026/01/01]

Introduction

【Sparkgigs】(referred to as "we") deeply understands the importance of personal information to you, and your trust is of great significance to us. We will protect the security of your personal information and privacy in accordance with the provisions of laws and regulations and with reference to industry best practices. We have formulated this "Privacy Policy" and specially remind you: please carefully read and understand this Privacy Policy before using 【Sparkgigs】 and its related services to make appropriate choices.

This Privacy Policy will help you understand:

1. We will collect and use your information in accordance with the Privacy Policy, but will not collect personal information in a package through a mandatory bundled approach solely because you agree to this Privacy Policy.

2. When you use or enable relevant functions or services, we will collect and use relevant information as necessary to realize the functions and services. Unless the information is necessary to realize business functions or required by laws and regulations, you may refuse to provide it without affecting other functions or services. We will specify the information to be collected item by item in the Privacy Policy.

3. To realize business functions or as required by laws and regulations, we will collect and use your sensitive personal information when you use specific functions or services.

4. This Privacy Policy applies to the products and services provided to you through web pages, H5, software development kits (SDK) and application programming interfaces (API) for third-party websites and applications, as well as innovative forms emerging with technological development. (Scope of Application) If you use certain services provided by us or our affiliated companies that have independent privacy policies, such services or products shall be subject to the corresponding privacy policies; if no independent privacy policy is established, this Policy shall also apply to such products or services.

The following will help you learn in detail how we collect, use, store, transfer (if applicable), and protect personal information; and how you can access, copy, correct, delete, and withdraw authorization of personal information. This Policy is closely related to your use of our services. We recommend that you carefully read and understand the entire content of this Policy and make the choices you deem appropriate.

Important clauses related to your personal information rights and interests have been highlighted in bold, so please pay special attention.

1. How We Collect and Use Personal Information

We will collect information actively provided by you when using the services, as well as information generated during your use of functions or acceptance of services through automated means, in the following ways:

1.1 Registration, Login, Authentication, and Account Recovery
1.1.1 Registration and Login

a. When you register for and log in to 【Sparkgigs】 and its related services, you can create an account via Google Email and complete relevant online identification information (avatar, nickname). Such information is collected to help you complete the registration. This Platform is only available to users who have completed the signing of the contract; if you have not completed online/offline signing of the contract, you will not be able to use the Platform smoothly. After registering and logging in to your account, you can fill in personal data (such as nickname), and we will collect the personal data you actively provide for Platform management.

1.2 Creator Operations

After completing the signing of the contract, you can log in to Sparkgigs, filter and search for short drama content in the corresponding promotion programs, and complete promotion objectives by shooting and posting content on other media platforms (including but not limited to YouTube, TikTok, etc.). We may collect your task selection information, promotion activity participation information, and other information you actively submit.

1.3 Operation and Security Assurance
1.3.1 Operation and Security Guarantee

We are committed to providing you with a safe and reliable product and usage environment, and delivering high-quality and trustworthy services and information is our core goal. To maintain the normal operation of our services and protect the legitimate interests of you, other users, or the public from losses, we will collect necessary information for maintaining the safe and stable operation of the products or services.

1.3.2 Device Information and Log Information

a. To ensure the safe operation, operational quality, and efficiency of the software and services, we will collect your hardware model, operating system version number, device identifier, network device hardware address (MAC address), IP address, software version number, network access method, type, status, network quality data, operation records, usage records, and service logs.

b. To prevent malicious programs and ensure operational quality and efficiency, we will collect information about installed applications or running processes, overall operation, usage, and frequency of applications, application crash information, overall installation and usage status, performance data, and application sources.

d. We may use your account information, device information, service log information, as well as information that our affiliated parties and cooperating parties are authorized by you or legally permitted to provide, to determine account and transaction security, conduct identity verification, identify illegal and irregular activities, detect and prevent security incidents, and take necessary recording, analysis, and disposal measures in accordance with the law.

1.4 Changes to the Purpose of Collecting and Using Personal Information

Please understand that as our business develops, the functions and services provided by 【Sparkgigs】 may be adjusted and changed. In principle, when new functions or services are related to the functions or services we currently provide, the personal information collected and used will have a direct or reasonable connection with the original processing purpose. In scenarios where there is no direct or reasonable connection with the original processing purpose, if we collect and use your personal information, we will separately inform you and obtain your consent in accordance with the requirements of laws, regulations, and national standards through page prompts, interactive processes, or agreement confirmations.

1.5 Exceptions to Obtaining Prior Authorization and Consent

Please understand that in the following circumstances, in accordance with laws, regulations, and relevant national standards, we may collect and use your personal information without obtaining your prior authorization and consent:

  1. Related to our performance of obligations stipulated by laws and regulations;
  2. Directly related to national security and national defense security;
  3. Directly related to public security, public health, and major public interests;
  4. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
  5. Necessary to protect your or others' major legitimate rights and interests such as life and property, but it is difficult to obtain the person's authorization and consent;
  6. Personal information that you have voluntarily disclosed to the public;
  7. Necessary for signing and performing contracts at the request of the personal information subject;
  8. Personal information collected from legally publicly disclosed information, such as through legitimate news reports, government information disclosure, and other channels;
  9. Necessary to maintain the safe and stable operation of the software and related services, such as detecting and handling faults of the software and related services;
  10. Necessary for conducting legitimate news reports;
  11. Necessary for academic research institutions to carry out statistical or academic research based on public interests, and when providing academic research results or descriptive results to the public, the personal information contained in the results is subject to de-identification processing;
  12. Other circumstances stipulated by laws and regulations.

We specially remind you that if the information cannot identify your personal identity independently or when combined with other information, it is not your personal information in the legal sense; when your information can identify your personal identity independently or when combined with other information, or when we use data that cannot be associated with any specific personal information in combination with other your personal information, such information will be treated and protected as your personal information in accordance with this Privacy Policy during the period of combined use.

1.6 Message Notifications

You acknowledge and agree that during operation, we may send you one or more types of notifications through the contact information you provided when using the products and/or services (such as phone number), for purposes such as message notifications, identity verification, security verification, and user experience surveys; in addition, we may also send you commercial information about services, functions, or activities that may be of interest to you via short messages or phone calls to the mobile phone numbers collected in the aforementioned process. However, please rest assured that if you do not wish to receive such information, you can unsubscribe through the unsubscribe method provided in the short messages or contact us directly to unsubscribe.

2. How We Use Cookies and Similar Technologies

Cookies, device information identifiers, and similar technologies are commonly used in the Internet. When you use 【Sparkgigs】 and its related services, we may use relevant technologies to send one or more Cookies or anonymous identifiers to your device to collect, identify, and store information about your access to and use of this product. We promise not to use Cookies for any purposes other than those stated in this Privacy Policy. We mainly use Cookies and similar technologies to achieve the following functions or services:

2.1 Ensuring the Safe and Efficient Operation of Products and Services

We may set Cookies or anonymous identifiers for authentication and security purposes to confirm whether you have logged in to the service safely or encountered theft, fraud, or other illegal activities. These technologies will also help us improve service efficiency and enhance login and response speeds.

2.2 Helping You Obtain a More Convenient Access Experience

The use of such technologies can help you avoid repeating the steps and processes of filling in personal information and entering search content (example: recording searches and form fillings).

2.3 Clearing Cookies

Most browsers provide users with the function to clear browser cache data, and you can perform corresponding data clearing operations in the browser settings. If you perform such clearing, you may not be able to use the services or corresponding functions provided by the Company that rely on Cookies due to these modifications.

3. Cooperating Parties Involved in Data Use, and Transfer and Disclosure of Personal Information

3.1 Cooperating Parties Involved in Data Use
3.1.1 Principles

a. Legality Principle: Data use activities involved in cooperation with cooperating parties must have a legitimate purpose and comply with legal validity bases. If the cooperating party's use of information no longer complies with the Legality Principle, it shall cease to use your personal information or use it only after obtaining the corresponding legal validity basis.

b. Legitimacy and Minimum Necessity Principle: Data use must have a legitimate purpose and be limited to what is necessary to achieve that purpose.

c. Security and Prudence Principle: We will carefully assess the purpose of the cooperating party's data use, comprehensively evaluate their security assurance capabilities, and require them to comply with the cooperative legal agreement. We will conduct strict security monitoring of the Software Development Kits (SDK) and Application Programming Interfaces (API) through which cooperating parties obtain information to protect data security.

3.1.2 Entrusted Processing

For scenarios involving entrusted processing of personal information, we will sign relevant processing agreements with the entrusted cooperating parties in accordance with legal provisions and supervise their personal information use activities.

3.1.3 Joint Processing

For scenarios involving joint processing of personal information, we will sign relevant agreements with cooperating parties in accordance with legal provisions, specify the respective rights and obligations of each party, and ensure compliance with relevant legal provisions and data security in the process of using the relevant personal information.

3.1.4 Scope of Cooperating Parties

If specific functions and scenarios involve services provided by our affiliated parties or third parties, the scope of cooperating parties shall include our affiliated parties and third parties.

3.1.5 Data Use for Realizing Functions or Services

d. When you use account-binding functions or related services, you may need to complete information authentication to verify your identity in accordance with relevant laws, regulations, and security assurance requirements. During the information authentication process, the certification service institutions cooperating with us will need to use your real name, ID card number, and mobile phone number. Some of this information is sensitive personal information; refusing the above use will result in your inability to complete information authentication, but will not affect the normal use of other functions of 【Sparkgigs】. Such information is only used for information authentication and purposes stipulated by laws and regulations, and will not be used for other purposes without your explicit authorization.

3.1.6 Data Use for Security and Analytical Statistics

a. Ensuring usage security: We attach great importance to account, service, and content security. To protect the account and property security of you and other users and safeguard the legitimate rights and interests of you and us from illegal infringement, our cooperating parties may use necessary device, account, and log information.

b. Analyzing product performance: To analyze the use and performance of our products, our cooperating parties may need to use information such as product usage (crashes, flashbacks), device identification information, and overall application installation and usage status.

c. To improve scientific research capabilities in relevant fields and promote the level of technological development, on the premise of ensuring data security and legitimate purposes, we may use de-identified or anonymized data with cooperating scientific research institutes, universities, and other institutions.

3.2 Transfer

As our business continues to develop, we may conduct mergers, acquisitions, or asset transfers, and your personal information may be transferred accordingly. In the event of the aforementioned changes, we will require the successor to continue to perform the obligations of the personal information processor in accordance with laws, regulations, and security standards no lower than those specified in this Privacy Policy. If the successor changes the original processing purpose or method, we will require the successor to re-obtain your authorization and consent.

3.3 Disclosure

a. We will not disclose your information unless required by national laws and regulations or with your consent. When disclosing your personal information, we will adopt security protection measures that meet industry standards.

b. When issuing penalty notices for violating accounts or fraudulent activities, we will disclose information about the relevant accounts.

3.4 Disclosure and Provision of Personal Information Exempted from Obtaining Consent in Accordance with the Law

Please understand that in the following circumstances, in accordance with laws, regulations, and national standards, we may provide or disclose your personal information to cooperating parties without obtaining your authorization and consent:

  1. Necessary for concluding and performing a contract where you are a party, or for implementing human resource management in accordance with legally formulated labor rules and regulations and legally signed collective contracts;
  2. Necessary for performing statutory duties or obligations;
  3. Directly related to national security and national defense security;
  4. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
  5. Necessary for responding to public health emergencies or protecting the life, health, and property safety of natural persons in emergency situations;
  6. Processing personal information within a reasonable scope for conducting news reports and public opinion supervision for public interests;
  7. Processing your voluntarily disclosed or otherwise legally publicly disclosed personal information in accordance with relevant legal provisions;
  8. Collecting personal information from legally publicly disclosed information;
  9. Other circumstances stipulated by laws and administrative regulations.

4. How We Store Personal Information

4.1 Storage Location

In accordance with the provisions of laws and regulations, we will store your personal information collected and generated during domestic operations within the territory of the People's Republic of China. Currently, we will not transmit the above information overseas. If we transmit it overseas, we will strictly comply with relevant Chinese laws and regulatory policies and follow relevant national provisions or obtain your consent.

4.2 Storage Period

We will only retain your personal information for the period necessary to provide 【Sparkgigs】 services, for example:

Email: When you register and log in using an email, we need to retain your email continuously to provide you with normal services, respond to your possible inquiries and complaints, and ensure the security of your account and the system.

Relevant information generated during your task selection and other links on this Platform: During the period when you have not fulfilled, terminated, or rescinded the contract, we will retain relevant information to provide you with continuous business functions.

If you cancel your account, take the initiative to delete personal information, exceed the necessary period, or after the contract is terminated or rescinded, we will delete or anonymize your personal information, except in the following cases:

  1. Complying with the requirements of laws and regulations on information retention (for example: the Electronic Commerce Law stipulates that commodity and service information, as well as transaction information, shall be retained for no less than three years from the date of completion of the transaction).
  2. Needing to reasonably extend the period for financial, auditing, dispute resolution, and other purposes.

5. How We Protect the Security of Personal Information

5.1 We attach great importance to the security of your personal information and will strive to take reasonable security measures (including technical and management aspects) to protect your personal information from improper use, or unauthorized access, public disclosure, use, modification, damage, loss, or leakage.

5.2 We will use encryption technology, de-identification processing, and other reasonable and feasible means no less than industry peers to protect your personal information, and use security protection mechanisms to prevent malicious attacks on your personal information.

5.3 We will establish a dedicated security department, security management system, and data security processes to ensure the security of your personal information. We adopt strict data use and access systems to ensure that only authorized personnel can access your personal information, and conduct regular security audits of data and technologies.

5.4 Despite having adopted the above reasonable and effective measures and complied with the standards required by relevant legal provisions, please understand that due to technical limitations and various possible malicious means, in the Internet industry, even if we do our utmost to strengthen security measures, it is impossible to always guarantee 100% information security. We will make every effort to ensure the security of the personal information you provide to us.

5.5 You acknowledge and understand that the systems and communication networks you use to access our 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 using complex passwords, changing passwords regularly, and not disclosing your account password and related personal information to others.

5.6 We will formulate emergency response plans and immediately activate the emergency plan in the event of a user information security incident, striving to prevent the expansion of the impact and consequences of such security incidents. In the event of a user information security incident (leakage or loss), we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly inform you of the relevant situation of the incident through push notifications, emails, letters, short messages, and other relevant forms. If it is difficult to inform each individual, we will issue an announcement in a reasonable and effective manner. At the same time, we will report the disposal of the user information security incident to the relevant regulatory authorities in accordance with their requirements.

5.7 Once you leave "【Sparkgigs】" and its related services to browse or use other websites, services, and content resources, we will have no ability or direct obligation to protect any personal information you submit on software or websites outside of 【Sparkgigs】 and its related services, regardless of whether you log in to, browse, or use the above software or websites through links or guidance from "【Sparkgigs】".

6. Managing Your Personal Information

We attach great importance to your management of personal information and make every effort to protect your rights to access, copy, correct, supplement, delete, withdraw consent and authorization, cancel your account, file complaints and reports, and set privacy functions with respect to your personal information, so that you have the ability to protect your privacy and information security.

6.1 Your Rights to Personal Information

Accessing and copying [personal account information]: You can access and copy your [avatar, nickname, settlement information] through [Platform] - [Personal Center], and you can [access, copy, and correct] such information through [Platform] - [Personal Center].

In addition to the above, if you or other authorized entities have any claims, requests, or questions regarding the exercise of personal information rights granted by relevant laws and regulations, you can contact us through [the operational staff of our Platform assigned to you]. We will review the relevant issues as soon as possible and respond within fifteen working days after verifying your user identity.

6.2 Canceling Your Account

You can contact us through [Platform Customer Service] to apply for canceling your account. We will process your application in a timely manner after receiving it and respond to your request within 15 working days or the time limit required by laws and regulations. Before canceling your account, we will verify your personal identity, security status, device information, etc. You acknowledge and understand that account cancellation is an irreversible action. After you cancel your account, we will delete or anonymize your relevant information, unless otherwise stipulated by laws and regulations.

Please also note that if your creator cooperation contract with us has not been terminated/canceled, you will not be able to complete the account cancellation; at the same time, the termination/cancellation of the creator cooperation relationship does not mean that the Platform account is automatically canceled.

6.3 Feedback, Complaints, and Reports

You can file complaints or reports in accordance with the publicly announced system. If you have any opinions, or if you believe your personal information rights may have been infringed, or if you discover clues of infringement of personal information rights, you can contact us through [Platform Customer Service].

6.4 Accessing the Privacy Policy

Please understand that the 【Sparkgigs】 and related services described in this Privacy Policy may vary depending on the mobile phone model, system version, software application version, mobile client, and other factors you use. The final products and services shall be subject to the 【Sparkgigs】 software and related services you use.

6.5 Notification of Suspension of Operations

If we suspend operations, we will promptly stop collecting your personal information, notify you of the suspension of operations through individual delivery or announcements, and delete or anonymize your personal information in our possession.

7. Provisions for Minors

Sparkgigs】 is mainly targeted at adults. If you believe that we have inadvertently collected a minor's information without permission, please contact us through the [contact information] at the end of this Policy so that we can delete such information as soon as possible.

8. Revisions and Notifications of the Privacy Policy

8.1 To provide you with better services, 【Sparkgigs】 and related services will be updated and changed from time to time. We will revise this Privacy Policy as appropriate. These revisions form part of this Privacy Policy and have the same legal effect as this Privacy Policy. Without your explicit consent, we will not reduce the rights you are entitled to under the currently effective Privacy Policy.

8.2 After this Privacy Policy is updated, we will publish the updated version on the 【Sparkgigs】 Platform and remind you of the updated content through announcements on the Platform or other appropriate methods before the updated clauses take effect, so that you can promptly understand the latest version of this Privacy Policy.

9. Contact Us

【Sparkgigs】 is provided by 【Beijing Yingliang Technology Co., Ltd.】. If you have any complaints, suggestions, or questions regarding personal information protection, you can send your inquiries to (Platform Customer Service).

We will verify your user identity and provide timely feedback on your complaints and reports.