We are fully aware of the importance of personal information to you, and will strictly abide by the relevant data protection laws and regulations in various applicable regions (including the EU General Data Protection Regulation GDPR, Brazil General Data Protection Law LGPD, Mexico Federal Personal Data Protection Law LFPDPPP, Colombia Personal Data Protection and Privacy Law PDPL, Argentina Personal Data Protection Law PDPL, Peru Personal Data Protection Law, Bolivia Consumer Protection Law, etc.). The purpose of this privacy policy is to explain to you how we collect, use, store, protect and share your personal information and the related rights you enjoy.

By using this service, you are deemed to have read, understood and agreed that we will handle your personal information in accordance with this privacy policy.

1. Personal information we collect

We only collect personal information necessary for providing this service, following the principle of “minimum necessity”, including the following two categories:

1.1 Information provided by you voluntarily

(1) Registration information: information provided when you register your account, such as mobile phone number and third-party account information (nicknames and avatars authorized when logging in through Google, Apple ID, Facebook, etc.); If the laws and regulations in your region (such as Colombia and Argentina) require real-name registration, it also includes the identity information that meets the requirements (such as ID number and passport information);

(2) Payment information: transaction records (including payment amount, payment time and payment channel) generated when you make internal purchases, and we do not store complete sensitive payment information such as bank card number;

(3) Customer service consultation information: the description, contact information and other information provided by you when you give feedback to customer service;

(4) Other information: user content such as comments and barrage released by you, and related information submitted when you participate in platform activities (such as event registration information).

1.2 Information we collect automatically

(1) Device information: including your device model, operating system version, device identifier (such as IMEI, Android ID and IDFA, which will be de-identified), IP address and network type (Wi-Fi/ mobile network);

(2) Usage behavior information: including the records of your watching short plays (viewing history, viewing duration, staying pages), search keywords, favorite contents, comments and likes, and advertisement clicks;

(3) Location information: We may collect your approximate geographic location (based on IP address) for providing localized content recommendation only after you explicitly authorize it, and you can withdraw this authorization in the APP settings at any time (we will delete the collected location information immediately after users in Peru and Argentina withdraw it);

(4) Advertisement-related information: After your explicit consent, collect the advertisement identifiers (such as GAID and IDFA) and installed application lists on the device for personalized advertisement push and effect statistics (Peru does not collect application list information unrelated to advertisements).

2. The purpose of using personal information

The personal information we collect is only used for the following purposes, and if it needs to be used beyond the following purposes, we will get your explicit authorization again:

(1) Provide and maintain this service: such as account management, content distribution, payment settlement, customer service response;

(2) Optimize the user experience: recommend personalized content according to your usage behavior (such as recommending short plays that you may be interested in), optimize APP functions, and fix faults;

(3) Safeguard service security: detect and prevent fraud, account theft, illegal use and other acts to protect your and our legitimate rights and interests;

(4) Push advertisements and marketing information: push relevant event notices, preferential information and personalized advertisements (with your explicit consent), and you can turn off marketing push at any time in the APP settings;

(5) Abide by laws and regulations: respond to regulatory requirements and cooperate with judicial investigation;

(6) Other: for other legal purposes with your explicit consent.

3. Sharing and transfer of personal information

3.1 Information sharing

We will not share your personal information with any third party unless:

(1) Obtain your express written authorization;

(2) It is necessary to perform this service, and the third party must sign a strict confidentiality agreement (such as payment service providers and cloud storage service providers), and only the minimum range of information required to complete the service can be obtained, and the third party must have the regulatory permission in the local area (such as Colombian payment service providers need to be authorized by financial regulatory agencies);

(3) Abide by laws, regulations or regulatory requirements, and cooperate with legal investigations by judicial organs and administrative organs;

(4) To protect the legitimate rights and interests of you or others, or to protect the normal operation of this service (such as responding to infringement complaints).

3.2 Information Transfer

In case of merger, acquisition, reorganization, asset sale and other transactions, your personal information may be transferred to a new entity. Before the transfer, we will notify you by APP announcement, pop-up window, etc. (Argentina will notify 30 days in advance and Bolivia will notify 15 days in advance), and ask the new subject to continue to abide by this privacy policy; If you don’t agree to the transfer, you can apply to cancel your account.

4. Storage and cross-border transmission of personal information

4.1 Storage life

We only keep your personal information to the extent necessary to achieve the purposes stated in this privacy policy:

(1) EU, Brazil, Mexico: Keep it for one year after the service is terminated, or for a longer period as required by laws and regulations;

(2) Argentina: the retention period shall not exceed 2 years (if it needs to be extended under special circumstances, it shall be approved by the local data protection agency);

(3) Colombia, Peru and Bolivia: reserved until 6 months after the termination of service, unless otherwise required by law;

(4) After the retention period expires, your personal information will be deleted or anonymized according to local regulations.

4.2 storage location

(1) Your personal information will be stored on the server in your area first: personal information in Colombia and Argentina needs to be stored on the local server (data localization requirements); The European Union, Brazil, Mexico, Peru and Bolivia give priority to regional servers that are stored locally or have “sufficiency identification”;

(2) If cross-border transmission is required, it will strictly abide by GDPR and the regulatory requirements of various applicable regions on cross-border data transmission, and adopt standard safeguard measures (such as European Union standard contract clauses SCCs, adequacy determination, etc.) to ensure that the protection level of the data receiver is substantially equal to that in China;

(3) Before cross-border transmission, you will be informed of the purpose of transmission, the receiver and the security measures separately through the APP pop-up, and your explicit consent will be obtained, and the Personal Information Protection Impact Assessment (PIA) will be completed.

4.3 Safety protection

We use a variety of security technologies and management measures to protect your personal information, including but not limited to HTTPS encrypted transmission, access control, security audit, virus protection, etc., to prevent personal information from being leaked, tampered with or lost. Please note, however, that there are certain security risks in any network transmission. We cannot completely guarantee the absolute security of information, so you should bear the corresponding risks yourself. In case of data leakage, we will notify you within the time limit stipulated by local laws and regulations (within 72 hours in the EU, 48 hours in Argentina and Colombia, and 7 days in Brazil and Mexico), and cooperate with the regulatory authorities in the investigation.

5. Your rights

According to the relevant data protection laws and regulations of each applicable region, you have the following rights to your personal information, which can be exercised through “APP-Settings-Privacy Center” or customer service channels:

Specific Rights and Exercise Rules

(1) Access: To inquire about and obtain your personal information, we will respond within the following time limits: within one month in the EU, within 45 days in Colombia, Peru and Bolivia, and within 30 days in Brazil, Mexico and Argentina;

(2) Right of correction: request to correct inaccurate and incomplete personal information, and the response period is the same as the right of access;

(3) Delete right: request to delete your personal information (unless otherwise stipulated by laws and regulations), and users in Argentina and Peru may request written confirmation after deletion;

(4) Withdraw authorization right: withdraw authorization for specific rights (such as location information authorization and marketing push authorization) at any time. After withdrawing authorization, we will no longer process your relevant information based on this authorization;

(5) Cancelation right: apply for cancelation of your account. After account cancelation, we will delete or anonymize your personal information (data deletion will be completed within 15 days after Colombia’s cancelation);

(6) Data portability: We are required to export your personal information in a structured and universal format (such as CSV and JSON), and the response period is the same as the access right;

(7) Right of complaint: If you think that our personal information processing behavior violates relevant laws and regulations, you can complain to the data protection regulatory authorities in your region (for example, the European Union complained to EDPB, Argentina complained to DNPDPC, Colombia complained to SDDP, and Peru complained to INDECOPI).

5.2 Precautions for Exercise

(1) In order to verify your identity, you may need to provide a registered mobile phone number, account ID and other information when exercising;

(2) If you are the guardian of a minor, you can exercise the above rights on your behalf and ask to delete the personal information of the minor;

(3) We will not discriminate against you or restrict you from using the core functions of this service because you exercise the above rights.

6. Information protection for minors

(1) “Minors” in the European Union refer to those under the age of 16, while those in Brazil, Mexico, Colombia, Bolivia, Peru and Argentina refer to those under the age of 18 (all defined by local laws and regulations);

(2) We don’t take the initiative to collect any personal information of minors. If it is found that personal information of minors has been collected by mistake, such information will be deleted immediately and the use of related accounts will be terminated;

(3) If you are the guardian of a minor and find that the minor has used this service and submitted personal information, you can contact us through the customer service channel and ask to delete the relevant information, enable the parental control function, or apply for returning the unauthorized consumption-related data processing records of the minor.

7. Changes in privacy policy

We have the right to update this privacy policy according to laws and regulations or modify it according to business needs. The revised privacy policy will be notified to you through the APP pop-up window and registered email address, and you have the right to raise an objection through the customer service within 15 days after the notice is delivered ((Argentina’s objection period is within 10 days after delivery, Bolivia’s objection period is within 20 days after delivery)); By continuing to use this service, you are deemed to have read, understood and agreed to the revised privacy policy. If you disagree with the revised privacy policy, you should stop using this service immediately.

8. Contact information

If you have any questions, complaints or suggestions about this privacy policy, or need to exercise the rights related to personal information, you can contact us in the following ways:

— Customer service email: servicio@ntzmcn.com

— Customer service telephone number:

— Company address: 7 Esparragal Street, Quismondo, Toledo 45514, Castilla-La Mancha, Spain

— Person in charge of data protection: name and contact information

Note: The above contact information will be updated through the APP announcement, subject to the latest announcement.