Zettlab Privacy Policy

Last Updated: August 6, 2026
Effective Date: August 6, 2026

Welcome to Zettlab! This Privacy Policy applies to the Zettlab products and services (as defined below) operated by Wuyun Innovation Technology Co., Ltd. and its affiliates. We sincerely thank you for your trust, and we are committed to handling your personal information strictly in accordance with applicable laws and regulations to protect your privacy and security. This Privacy Policy (this “Policy”) is intended to help you understand how we collect, use, share, protect, and store your personal information, so that you can clearly understand how to effectively manage your personal data when using our products and services and make more informed decisions. This Policy applies to all products and services provided by Zettlab, including the various applications associated with Zettlab (such as mobile, desktop, TV, and WeChat applications).

This Policy specifically explains how Zettlab collects and uses your personal information, in particular the rules governing data management when you use our network-attached storage devices (“NAS”) and related applications.

Before using our products or services, please read this Policy carefully, paying special attention to the sections in bold, to ensure that you fully understand and agree to it before you begin using our services.

In addition to this Policy, we may notify you in real time, through pop-up windows, on-page notices, or similar means, of the purpose, scope, and manner of use of the information collected. Such real-time notices and updates constitute an important part of this Policy and have the same legal effect as this Policy.

We strive to make all the terms of this Policy clear and easy to understand. If you have any questions, feedback, or suggestions regarding this Policy, you may contact us using the contact information provided at the end of this Policy.

By accepting this Policy, you acknowledge the functions of Zettlab and agree that we may collect the personal information necessary to provide our services to you. When you enable or use specific features of Zettlab, we will process your personal information based on your choices or as required by law. Other than the basic data required for core functions and services, you have the right to refuse additional data collection, but please note that doing so may affect your ability to use certain features or services.

This Policy will help you understand the following:

Scope of Application
How We Collect and Use Your Personal Information
Permissions
Use of Cookies and Similar Technologies
How We Store and Protect Your Personal Data
Handling of Information Security Incidents
How We Share, Transfer, and Publicly Disclose Your Personal Information
Legal Basis for Processing Personal Data
About the User Experience Improvement Program
Cross-Border Transfer of Data and Personal Information
Processing of Minors’ Personal Information
Updates to This Policy
Contact Us

1. Scope of Application

In this Policy, “Zettlab” refers to all products and services accessed and used through the Zettlab client, including websites, the Zettlab software development kit (SDK) and application programming interface (API) used for third-party websites or applications, mini-programs, and any new products or services added as a result of technological advancement. Different versions of Zettlab may have different functions and services; unless otherwise specified for a particular version, we will collect and process your personal information in accordance with this Privacy Policy. If a specific version of Zettlab has a separate privacy policy, that privacy policy will also apply; in the event of any conflict between this Policy and the privacy policy of a specific version, the version-specific policy shall prevail. Please note that certain operations and features may differ between versions of Zettlab; the version you actually use shall govern.

This Policy applies only to Zettlab’s own products and services. Third-party services are governed by their own privacy policies and data collection practices and are not covered by this Policy.

2. How We Collect and Use Your Personal Information

We collect and use the personal information you provide, personal information generated through your use of Zettlab’s products and services, and personal information obtained from third parties with your consent, in order to provide you with Zettlab’s services, communicate with you, and improve our products and services. As our products develop, new features or services may emerge; if we intend to use your information for a purpose not covered by this Policy, or to use information collected for a specific purpose for another purpose, we will notify you in a reasonable manner and obtain your consent again before such use, except where consent is not required by law. [You may quickly review the details of the personal information we collect by accessing the Zettlab Personal Information Collection List.]

The scenarios in which we collect personal data from you, the categories of information involved, and the manner and purpose of collection are as follows:

Account Registration

You need to register a Zettlab account to log in to and centrally manage the network-attached storage devices (“NAS devices”) manufactured and sold by Wuyun. To do so, you need to provide your mobile phone number (for users in mainland China) or email address (for users in other countries or regions) to receive a verification code to verify your identity, and to set your password, as well as other identity information (such as an avatar and nickname). We collect this information to help you complete registration and login of your Zettlab account, to enrich your account information, to protect and maintain your account security, to facilitate account recovery, and to bind your NAS device based on the basic information you provide; we may also send important device notices via SMS or email. If you do not provide this information, you will not be able to use the related services and features that require a Zettlab account.

While you use a NAS device, Zettlab cannot access any personal data (such as photos, documents, or videos) stored on your device; such data can only be accessed by you or friends you authorize. You may log in using a local account, which includes administrator and non-administrator accounts; when you choose to log in with a local account, all data is stored only on your NAS device and your phone (or computer), and Zettlab will not collect any personal data stored on the device.

Account Login

To protect account security and prevent unauthorized access, we collect your login records to quickly identify abnormal behavior and reduce potential security risks, specifically including:

Operation records: records of operations such as login and unbinding, to facilitate account security management;

IP address: used to precisely locate the network login location (down to the city level);

Operating system: identifies the system used to log in (e.g., iOS, Android, macOS, Windows);

Access method: used to precisely locate the network login location via IP address (down to the city level).

Device Binding and Management

To successfully bind and manage your Zettlab device, we need to collect the following information: device model, device serial number (SN), MAC address, IP address, remote connection ID (when remote connection is enabled), custom device name, device system status (online/offline/sleep), device ownership role (owner/sharer), and warranty expiration date (visible to administrators only). This information helps you complete device binding, identify devices, associate devices with your account, ensure that bound devices can be queried and managed, and monitor device status in real time, while ensuring that device management permissions are correctly assigned. For device administrators, we also collect the warranty expiration date so that we can remind you in a timely manner to arrange warranty service.

Trusted Device Feature

To improve login convenience and security, Zettlab allows you to designate “trusted devices,” which can skip repeated identity verification and simplify the login process while maintaining security and improving the login experience for trusted devices.

Login information collection: to enhance account security, we record the device model and name, login location (based on IP, down to the city level), and most recent login time, to help verify login behavior and take necessary security measures;

User management: you may view your login records and list of trusted devices, and you have the right to delete any suspicious device; if abnormal behavior is detected, we recommend changing your password and removing suspicious devices to protect your account;

Account security enhancement: by monitoring login records, we can effectively prevent unauthorized access; if the system detects an abnormal login attempt or security threat, it will immediately take corresponding measures, including notifying you and implementing further protective measures;

Trusted device management: you may manage your trusted devices at any time, reduce frequent verification requests, and easily remove suspicious or outdated devices.

IP-Based LAN Device Search

When you use the IP connection on your NAS device’s display and activate the local area network (LAN) device search feature, we will collect information about devices on the same LAN, including device name, IP address, MAC address, serial number, operating system version, device model, and status (online or connected), to help you accurately identify and efficiently manage your LAN devices and provide a convenient user experience.

Remote Connection Service

You may choose to enable the remote connection feature to quickly connect to your NAS device remotely. To provide this feature, we will collect the following information from your NAS device:

Product serial number
IP address
Router port

This information is essential to establishing a secure remote connection and optimizing the user experience. The serial number helps ensure a precise and secure association with your Zettlab cloud account, enabling you to use the remote connection service; when the remote connection feature is enabled, we also collect your IP address and router port information to support remote device connection and facilitate remote management of your Zettlab device.

Please note that we will only collect the information described above if you choose to enable the remote connection feature; if you choose not to use this feature, Zettlab will not collect or use such information.

When the remote connection service is enabled in a LAN environment, we will additionally collect the following device-specific information to ensure a stable and smooth connection experience when you access your device within a LAN environment:

IPv4 address and IPv6 address
MAC address
DDNS address
Device status (initialized or not, online or not)
Wake-on-LAN (WOL) switch status
Device host name
Device boot time
Cloud Storage Services

If you choose to integrate Zettlab with a third-party cloud storage service (such as OneDrive, Dropbox, or Google Drive), we will automatically collect your cloud storage account information, including account name, avatar, membership level, and cloud storage capacity, to enable synchronization and transfer of files between Zettlab and the third-party cloud service.

We will request the necessary file read/write permissions from you or the cloud storage service provider to ensure smooth file upload, download, and task synchronization with the third-party cloud storage service; please note that such permissions are used only for file transfer and synchronization tasks and not for any other purpose. You may decide for yourself whether to link Zettlab with a third-party cloud storage service; declining to do so will not affect your use of other Zettlab features.

Operations and Security

To ensure the stable and secure operation of our products and services and to protect the legitimate rights and interests of users, the public, and ourselves, we may collect the following information:

Hardware and Network Information

To ensure the safe and efficient operation of our software and services, we will automatically collect your device information, including but not limited to:

Hardware model
Operating system version
Device identifiers (e.g., for Android devices: IMEI, IMEID, AndroidID, OAID, IMSI, SIM card information, GAID, and hardware serial number; for iOS devices: IDFV and IDFA)
Network device hardware address
IP address
WLAN access point information
Bluetooth device information
Base station information
Software version
Network access method and quality
Operation and usage log data
Service log data

This data helps ensure the normal operation of devices and services, maintain security, and provide a better user experience.

Use and Sharing of Account, Device, and Service Logs

We may use, and share with affiliates or partners, your account, device, and service log information for the following purposes:

Account security assessment
Identity verification
Detection of violations
Prevention of security incidents
Recording, analysis, and handling of violations
Collection and analysis of error logs

When an abnormal error occurs in Zettlab, in addition to the information above, we may automatically collect error log data to help analyze and resolve the issue and help you resume normal use as soon as possible.

Technical Support

To ensure that you have a stable and smooth connection experience when accessing devices in a LAN environment, we collect the following information:

Automatically collected device information: including device serial number (SN), Zettlab device system version, network status (e.g., IP address, network connection status), operation logs (records of system activity and user-initiated operations), and client information (operating system type and version, software version, etc.);
Access to personal files: our technical support team may access personal files stored on your Zettlab device only after you have expressly authorized and granted the relevant permission.

The purposes of collecting this information include:

Efficient technical support services: quickly locating and resolving issues by collecting device information, in order to provide you with accurate technical support;
Limited user permissions: our technical support team will initially request standard user permissions to ensure that access to device information is limited to what is necessary;
Comprehensive diagnosis: for complex technical issues, we may request additional permissions to better diagnose the problem, including creating and providing an administrator account for the technical support team to access the device; in such cases, your personal files will be accessed only with your express consent.
User Experience Research

Zettlab may invite you to participate in user experience research to continuously improve our products and services and enhance user satisfaction.

Collection of email address: we may invite you to provide your email address so that we can send you a survey to help us understand your experience with and feedback on Zettlab; participation in the survey is voluntary, and you may choose whether to provide this information;
Distribution of surveys: once you agree to participate, we may send the survey to your email address to collect your feedback, preferences, and suggestions regarding Zettlab products, in order to improve and optimize our products;
Marketing information: in addition to surveys, we may send marketing information to your email address, but only after obtaining your express consent.

Before conducting any user experience research or sending marketing information, we will seek your consent in advance, and we will not send any survey or marketing materials without your express consent.

Configuration Backup and Restoration

To make it convenient to save and restore device settings, you may use the “Configuration Backup and Restoration” feature. When a device is being repaired or migrated from one country/region to another, you may proactively restore the backed-up data. When this feature is enabled, we will automatically collect and use the following configuration information:

Connection and access information: including users and user groups (permissions and advanced settings), file services, device connection data (such as remote ID, DDNS, and portal settings), terminal devices, domain and LDAP configurations, etc.;
General settings: such as time and language, notifications, network, security, indexing services, etc.;
System services: such as system updates, resets, and configuration backup and restoration.
Processing Personal Information Under Statutory Circumstances

In accordance with applicable laws and regulations, we may automatically collect and use your personal information under the following lawful circumstances:

With your consent;
To perform a contract requested by you;
To fulfill statutory obligations such as anti-money laundering, counter-terrorism, and anti-telecom-fraud obligations;
In connection with requests related to national defense and security;
To respond to a public health emergency or to protect life, health, or property;
In connection with criminal investigation, prosecution, trial, or enforcement of judgments;
Personal data that you have voluntarily made public;
Information disclosed from lawful public sources, including news reports and government disclosures;
To ensure the safe and stable operation of our products/services, including fault detection and repair;
Other circumstances provided by law.

Please note that under items 2 through 10 above, we will process your personal data in accordance with law without separately obtaining your consent or authorization.

Other Third-Party Services and Independent Specialized Services

Zettlab includes information that we have lawfully obtained or linked to, as well as other independent services that we are authorized to operate, which may appear within Zettlab as standalone features (such as the Zettlab App Center). Zettlab may also integrate or include links to third-party content. In order to expand our services or improve the user experience, we reserve the right to adjust the content, form, or specific parts of these independent services at any time; we will make reasonable efforts to notify users in advance, although in some cases such adjustments may take effect immediately.

You may activate and use the independent services or features described above through Zettlab; doing so may require you to enter into an additional agreement with, or accept separate terms from, the service provider; the specific service provider and applicable agreement can be found in the independent service agreement or related information within the service. Where necessary, we will provide reasonable access to such agreements or terms for your review.

Some services or features within Zettlab may be provided independently by, or in cooperation with, third parties, and such services may require a separate user agreement, privacy policy, or other binding rules. Before using a third-party service, please carefully read the relevant agreement and rules to ensure that you fully understand and agree to them and have assessed the potential risks. When using third-party websites or applications, please exercise your own judgment and assess the risks involved; any disputes, damages, or losses arising therefrom shall be resolved directly between you and the relevant third party, and Zettlab shall not be liable for any direct or indirect damages caused by third-party services.

Please note that certain third parties may use your account ID to collect and process data; the third-party service provider is responsible for the collection, storage, use, and transmission of such data, and Zettlab does not participate in, control, modify, or access such data processing. When using third-party services, the security of your personal information and data is governed by the terms and policies of the relevant service provider.

If you have any questions about a third-party service provider’s agreement or terms, we recommend that you consult a legal expert or other professional before activating the third-party service. Zettlab may not be able to directly notify you of changes to third-party agreements or terms, so we recommend that you periodically review the agreements or terms of any third-party services you use to protect your own rights and interests.

3. Permissions

In providing our services, Zettlab may request certain permissions; please note that Zettlab does not enable these permissions by default and will only use a permission to collect your data after obtaining your express consent and authorization, and only where genuinely necessary. Granting Zettlab a specific permission does not mean that we will automatically collect your data; we will collect data only where it is lawful, valid, and necessary to do so.

If you decline to grant certain permissions, this may affect features that rely on that permission, but it will not affect your ability to use other features of Zettlab. For more details on permissions, please refer to the NAS Device Permission Request and Use Notice.

4. Use of Cookies and Similar Technologies

Cookies are a common internet technology used to improve the user experience of products and services, enhance security, speed up login, and optimize response time, among other purposes. We guarantee that we will not use cookies for any purpose other than those set out in this Privacy Policy.

We use cookies, device identifiers, and similar technologies to collect and identify your data.

Most browsers allow you to delete cookies, and you may clear cookie data in your browser settings; however, please note that deleting cookies may affect certain features or services that rely on this technology.

We undertake not to use cookies for any purpose other than those described in this Policy. We primarily use cookies and similar technologies to make it easier for you to use our products and services, to ensure the security and efficient operation of our products and services, to speed up login and response times, and to provide you with a more convenient access experience. If you use the web version of Zettlab, most browsers provide a feature allowing you to clear browser cache data; you may clear cookie data in your browser settings, but after doing so you may be unable to use certain features or services that rely on cookies.

5. How We Store and Protect Your Personal Data

5.1 Data Retention Period

We will retain your personal information only for the minimum period necessary to achieve the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. If you wish to have your personal information deleted, please contact us using the contact information provided in this Policy.

Our data retention standards are as follows:

(1) The length of our ongoing relationship with you and the period during which we provide Zettlab products and services to you (e.g., the period during which you hold a Zettlab account or continue to use Zettlab products); (2) whether you have modified, or other users have deleted, information through their accounts; (3) whether we have a legal obligation to retain the data (e.g., certain laws require us to retain your transaction records for a specified period before deletion); or (4) whether retention is advisable from our legal standpoint (e.g., in connection with enforcing our agreements, resolving disputes, applicable limitation periods, or litigation or regulatory investigations).

5.2 Security Measures

We take the security of your personal information seriously and have adopted industry-standard technical and administrative measures to protect your data, including:

Using encryption technologies (such as secure transmission protocols) to protect data during transmission;
Encrypting and isolating your data in storage;
Applying data de-identification techniques such as encryption and substitution to enhance data security; and
Implementing strict data access controls and multi-factor authentication to ensure that only authorized personnel can access your information.

The internet is not an absolutely secure environment, and even though we make every effort to strengthen our security protections, we cannot always guarantee the absolute security of information. Please understand that when using our products and services, security issues beyond our control may arise as a result of malicious attacks or similar events.

5.3 User Cooperation

We recommend that you take additional measures to protect your personal information, including:

Using strong passwords;
Changing your password regularly;
Properly safeguarding your account information.

These measures will help further enhance the security of your account and personal data.

6. Handling of Information Security Incidents

In the event of a personal information security breach, we have established an emergency response plan and will immediately activate it, form a team to investigate the cause, take all reasonable steps to minimize the resulting harm, and report to the relevant authorities as required by law. We will notify you of the basic facts of the incident, our assessment of its impact, our response measures, and any possible remedial measures, through the contact information you have provided (such as email, phone, or in-platform notifications). Where it is not practicable to notify each affected individual, we will issue a public announcement in a reasonable manner.

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

7.1 Use of APIs and SDKs

Zettlab integrates third-party SDKs and APIs, and such third parties may collect and process your personal information. We monitor and evaluate third-party SDKs/APIs to ensure compliance with security and legal requirements; however, please note that such third parties will process your data in accordance with their own privacy policies, and we recommend that you review their privacy policies before using the relevant services. This Privacy Policy does not apply to third-party services.

7.2 Information Sharing

We will not share your personal information with any company, organization, or individual outside of Zettlab or its affiliates, except in the following circumstances:

With your express authorization;
Where required to perform your service agreement (including any third-party services you choose to use through links within Zettlab) or our usage rules;
Where required by law, such as disclosure required by judicial or administrative authorities pursuant to statutory procedures;
In connection with legal proceedings, where we may initiate litigation or arbitration to protect our legitimate rights and interests;
To protect legitimate rights and interests, in order to prevent acts that infringe the legitimate rights and interests of Zettlab or other users; or
For academic research purposes.

7.3 Information Transfer

We will not transfer your personal information to any entity outside the Zettlab group, except in the following circumstances:

With your prior express consent;
To fulfill a statutory obligation; or
In connection with a merger, acquisition, bankruptcy liquidation, or similar event, in which case your information may be transferred as part of the transaction; we will keep the transfer process confidential and require the transferee to continue to comply with this Privacy Policy.

7.4 Public Disclosure of Information

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

With your express consent; or
As required to comply with applicable law, statutory procedures, or a mandatory requirement of a competent government authority.

7.5 Sharing, Transfer, and Disclosure Without Prior Consent

In the following circumstances, we may share, transfer, or publicly disclose your personal data without obtaining prior authorization:

National defense and security: directly related to national security;
Public safety and health: involving a major public interest;
Criminal investigation and law enforcement: such as criminal investigations or court orders;
Protection of others’ legitimate rights and interests: to protect important rights such as life or property;
Publicly available information: personal information that you have voluntarily made public; or
Lawful public sources: such as news reports or government-disclosed data.

7.6 How to Exercise Your Personal Information Management Rights

Use of a Local Account

If you register or log in using a local account, your data is stored on your own device (such as a phone or computer), and in this case we do not collect your personal data. You may manage your information at any time through the following steps:

Access path: Avatar > Home, or Control Panel > User Management;
Modification path: Avatar > Home, or Control Panel > User Management;
Changing or withdrawing consent:
Access path: Avatar > Privacy Management > System Permission Management;
Mobile devices: Avatar > Privacy Management > Privacy Statement > Withdraw Consent;
Deletion: log in with an administrator account, go to Control Panel > User Management to delete a user, or restore the device to factory settings.
Changing the Scope of Authorization or Withdrawing Consent
Changing permission authorization: Avatar > Privacy Management > System Permission Management;
Withdrawing consent on mobile: Avatar > Privacy Management > Privacy Statement > Withdraw Consent;
Declining or withdrawing marketing consent: you may unsubscribe from marketing communications at any time;
Deleting personal information: delete device information through your account settings on the official website.
Deletion Requests

If you request deletion of your personal information, we will process your request within 15 business days; after deletion, your personal data will no longer be used. However, in order to comply with legal or policy requirements, certain data may not be deleted immediately and will instead be stored or backed up for the statutory period before being permanently erased.

Obtaining a Copy of Your Personal Information

You have the right to request a copy of the personal information we hold about you. To submit such a request, please email:

Request email: inform@zettlab.com

Automated Decision-Making Based on Information Systems

Certain features may involve automated decision-making (implemented through information systems or algorithms). If you believe that such a decision affects your legitimate rights and interests and you wish to request an explanation or correction, please contact inform@zettlab.com for further assistance.

Responding to Your Requests Above

Response time: for security purposes, you may be required to submit a written request or provide additional proof of identity. We will process and respond to your request within 15 business days.

Free of charge: reasonable requests will generally be processed free of charge;

Refusal of unreasonable requests: we reserve the right to refuse requests that are unreasonable, repetitive, or technically burdensome;

Circumstances in which requests will not be accepted: in accordance with legal requirements, we may decline to accept the following requests:

Requests related to statutory obligations;
Requests related to major public interests such as national defense, national security, public security, or public health;
Requests related to legal proceedings such as criminal investigation, prosecution, or trial;
Malicious requests or requests that abuse rights;
Requests made to protect the life, property, or other important rights of others; or
Requests related to trade secrets.

8. Legal Basis for Processing Personal Data

We always process your personal data in accordance with the principles of lawfulness, transparency, and fairness. Depending on the type of data and the context of use, Zettlab may process your personal data on one or more of the following legal bases:

Necessity for the provision of services: personal data that must be processed in order to provide you with the services you have selected;
Specific consent, which may be withdrawn: where cookies are used to display advertisements or analyze website usage, we obtain your consent in advance; you may withdraw your consent at any time through cookie settings;
Compliance with legal obligations: processing personal data to comply with applicable laws and regulations, including responding to requests from government, judicial, or regulatory authorities and combating fraud and other unlawful activities;
Protecting your interests or the interests of others: processing personal data based on legitimate interests, including:
- Agreement rights: your use of the Zettlab application constitutes your acknowledgment and acceptance of the user agreement; if you do not agree to any amendment, you should stop accessing Zettlab’s services and consider discontinuing use;
- Performance of contracts: such as issuing invoices or providing support;
- Developing, testing, and optimizing our products and services;
- Protecting the security of accounts, activities, and products/services;
- Distributing marketing information related to our products and services;
- Complying with applicable laws outside the European Economic Area (EEA).

9. About the User Experience Improvement Program

We invite you to participate in our User Experience Improvement Program. This feature is turned off by default and will only be enabled with your explicit consent. Once you turn on the “User Experience Improvement Program,” we will collect desensitized or de-identified information regarding device operating status, feature usage, performance metrics, and exception diagnostics, for the purpose of improving the product experience, enhancing system stability, and optimizing service quality.

We report the following two categories of data:

Product Experience Tracking
- App launch, login, page visits, time spent on pages, and page navigation sources;
- Usage of feature entry points, buttons, and similar elements;
- Client environment information: app version, system type/version, device model, network type, and screen resolution;
- The version number and serial number of the currently connected NAS device;
- Randomized device identifiers, session IDs, and desensitized user identifiers used for session analysis and issue localization.
Operating Status and Diagnostic Logs
- App/API call chain information: request URL, HTTP method, status code, duration, and error code;
- NAS service operating status, system operating status, and information from OpenTelemetry traces/metrics/logs that is necessary for stability and performance diagnostics;
- Information related to crashes, errors, and performance anomalies;
- Logs are uploaded in sharded log packages; only diagnostic logs in designated log directories are uploaded, and user data directories are not scanned or packaged;
- Log content is desensitized and filtered for sensitive fields before upload, and is used only for product improvement and issue diagnosis.
We expressly commit to the following privacy boundaries:
- We will not upload your user files stored on the NAS, including the files themselves such as photos, videos, documents, or archives;
- We will not upload file content, the body of documents, image/video content, or thumbnails/previews;
- We will not upload your search terms and your AI conversation and AI analysis content;
- We will not upload account passwords, tokens, authorization credentials, cookies, keys, or other credentials; and
- We will not treat the NAS storage directory as a log directory and package it for upload.

You may turn off the “User Experience Improvement Program” in settings at any time. After turning it off, we will stop collecting non-essential product experience tracking and diagnostic data; however, to ensure device security, basic service availability, version checks, and fault recovery, the system may still process the necessary security and basic operational data.

10. Cross-Border Transfer of Data and Personal Information

10.1 Zettlab’s servers are deployed in mainland China, and Wuyun is committed to processing your data in accordance with the laws and regulations of mainland China to ensure the security of your data. [The data or other personal information we collect when you use Zettlab’s services (excluding independent specialized services or third-party services — please carefully read the corresponding privacy policy when using such services) will not be transferred outside mainland China (“overseas”).]

10.2 Your uploading and downloading activity to and from Zettlab hardware may involve cross-border data transfer; such activity is entirely within your own control, and Wuyun cannot ensure that you will be able to access or use such features outside mainland China and, as a practical matter, has no means of accessing or being aware of such activity. You should ensure that any cross-border transfer of data complies with the requirements of applicable laws and regulations governing data export.

11. Processing of Minors’ Personal Information

Our products and services are primarily intended for adult users. If you are under the age of sixteen (referred to in this Privacy Policy as a “minor”), please ensure that you use our services and share information with us only with the express consent of your parent or guardian. We are committed to protecting the personal information of minors and require parents or guardians to ensure that minors use our services only with their authorization.

Collection of minors’ personal data: we will collect and process a child’s personal information only after obtaining the express consent of a parent or guardian;

Use and disclosure of data: once we have collected a minor’s personal data, we will use or disclose it only with the consent of the parent or guardian or as required by law to protect children;

Deletion of minors’ personal data: if you believe that we have collected a minor’s personal information without the consent of a parent or guardian, please contact inform@zettlab.com, and we will verify and delete the relevant data.

12. Updates to This Policy

Wuyun may periodically update this Privacy Policy to reflect changes in our service model or data processing practices. We will notify you of material updates through push notifications, email, pop-up windows, or similar means, and will seek your consent where necessary. Material changes include:

Material changes to our service model, such as changes to the purpose, type, or manner of processing personal information;
Material changes in ownership or organizational structure, such as business restructuring, bankruptcy, mergers, or acquisitions;
Changes in the recipients of shared, transferred, or disclosed personal information;
Material changes in the manner in which personal information is processed or in how users interact with our services; or
A security assessment indicating a high risk to users’ personal information.

By using our services, you agree that we may collect, use, store, share, manage, and protect your information as described in this Privacy Policy.

13. Contact Us

If you have any questions, comments, or suggestions regarding this Privacy Policy or our services, you may contact us as follows:

Dedicated Data Protection Officer: please email
inform@zettlab.com

To enable us to process your inquiry efficiently, please provide proof of identity, valid contact information, a written request, and any relevant supporting evidence. We will process your request within 15 business days.