one2free account privacy policy

Updated April 10, 2026

Release Date: April 10, 2026

Effective Date: April 10, 2026

Update Reminder

Thanks for using one2free account, we've updated our one2free account privacy policy to include:

1. Improved the necessity of collecting relevant personal information and the expression of the use of the third party SDK, so that you can more clearly and clearly understand the purpose and method of collecting your personal information and other details;

2. In accordance with this Privacy Policy 5. Exceptions for obtaining prior authorization and consent when sharing, transferring, or publicly disclosing personal information are listed in "V. How we store your personal information";

3. The formulation of some sections such as Introduction, Definition and Interpretation has been adjusted to make it easier for you to read and understand our principles for handling your personal information more clearly, clearly and smoothly.

Please note that this update does not involve a change in the type, purpose and manner in which we process your personal information, and we will not reduce your rights under this policy without your explicit consent.

Introduction

The one2free Account Privacy Policy (the “Policy”) applies only to one2free account services (account registration, login and management services) provided to you by one2free Co., Ltd. and its affiliates (“one2free” or “we”). Please read this policy carefully before using your one2free account for details on how we process your personal information. Please pay special attention to the sensitive personal information and important content related to your personal information rights, which we have notified in bold form. If you are a minor, please carefully read and fully understand this policy, accompanied by your parent or other guardian, and use the one2free account service with the consent of your parent or other guardian.

As a reminder, this policy describes how we treat personal information you provide to us when you use your one2free account, but it does not cover all scenarios where you log in to a product or service using your one2free account. At the same time, you can also use the basic functions of the product in a non-registered/logged-in state, unless registration and logged-in are required for our corresponding product to provide its basic functions. Therefore, we recommend that you carefully read the privacy policy of the corresponding product or service to understand the specific rules for their handling of your personal information.

I. Definition and Interpretation

1. one2free account service: refers to the account registration, login and management service provided by one2free, the operator of one2free account, hereinafter referred to as the "service". One2free account is an identification owned by one2free to identify users, you can use one2free account to access/use/purchase various application products, services, and websites provided by us. You can use the one2freeAI agent input method by logging into your one2free account. You can also purchase our various virtual products and value-added services through your one2free account.

2. British Virgin Islands Lita Digital Co., Ltd. hereinafter referred to as “we”).: Operator of one2free account, specializing in intelligent voice and language technology research, software and artificial intelligence product development, voice information services and e-government system integration. If you would like to learn more about our company and platform, you can contact us through the contact details provided in chapter 9 of this policy.

3 User: refers to the user who registers, logs in and uses the Service and enables, browses or uploads data to the one2free account service, more commonly referred to as “you” in this policy.

4. Account: refers to the user account you enjoy after completing the real information registration, and the user account is kept by you; you shall be legally responsible for all actions carried out under your account.

5. Personal information: Personal information is various information related to identified or identifiable natural persons recorded electronically or otherwise, excluding information after anonymization. For the avoidance of doubt, personal information includes, but is not limited to, sensitive personal information.

6. Sensitive personal information: Sensitive personal information is personal information that, once leaked or illegally used, is likely to cause an infringement on the personal dignity of natural persons or endanger the safety of persons and property, including biometrics, religious beliefs, specific identities, medical health, financial accounts, whereabouts and other information, as well as personal information of minors under the age of 14.

7. Processing of personal information: The processing of personal information includes the collection, storage, use, processing, transmission, provision, disclosure, deletion, etc. of personal information.

8. Personal Information Processors: Personal information processors refer to organizations and individuals that independently determine the purpose and manner of processing in their personal information processing activities.

9. Personal Information Subject: Personal information subject refers to the natural person identified or associated with the personal information.

10. De-Identification: De-Identification refers to the process of processing personal information so that it cannot identify a specific natural person without the help of additional information.

11. Anonymization: Anonymization refers to the process in which personal information is processed so as not to identify a specific natural person and cannot be recovered.

12. Devices: Devices are devices that can be used to access one2free account services, such as desktop computers, laptops, tablets, or smartphones.

13. Unique Device Identifier: A unique device identifier (unique ID or UUID) is a string of characters that is compiled into a device by the device manufacturer and can be used to uniquely identify the corresponding device (IMEI number of the mobile device). Unique device identifiers can be used for a variety of purposes, including serving advertisements when cookies are not available.

14. IP Address: Each Internet-connected device is assigned a number, called an Internet Protocol (IP) address. These numbers are usually assigned based on geographic regions. An IP address can often be used to identify where the device is when connected to the Internet.

15. SSL: SSL (Secure Socket Layer), also known as Secure Socket Layer, is a security protocol implemented on the Transport Communication Protocol (TCP/IP). SSL supports various types of networks and provides three basic security services, all of which use public keys and symmetric key technology to achieve information confidentiality.

II. How WE collect and use your personal information

As processors of personal information, we will collect and use your personal information for the purposes described below, in accordance with the principles of legality, propriety, necessity and integrity.

1. Personal information you voluntarily provide in the course of providing services to you

1.1 In order to achieve our basic business functions, you only need to provide us with the basic necessary personal information corresponding to that function, except for the special requirements of relevant laws, regulations and normative documents. If you decline, we will not be able to provide you with the appropriate service. Note: If you provide personal information that is not your own, please ensure that you have obtained the consent of the relevant subject. Our basic business functions include:

Register & Login

When registration/login is necessary for our corresponding product/service to provide its basic functions, in order to ensure the safety of your personal space, you need to register and log in to "one2free account" to access/use/purchase our corresponding product/service by using the account. You'll need to provide us with your one2free account name when you sign up and log in. This information is required for registration and login. If you do not provide it, you will not be able to use the one2free account service. You can also set a password for your one2free account. Your account number and password will be kept encrypted on the server and can only be used by you. We recommend that you keep your password information safe to prevent your one2free account from being stolen by others.

Feedback

When you provide feedback through our customer service regarding a complaint, appeal, or inquiry related to one2free account services, in order to ensure the security of your account and the system, you need to provide us with the account number (phone number or email address) where you registered/logged in so that we can verify your user identity. During the feedback, complaint, or inquiry process, in order to help you resolve the issue or document the resolution and outcome of the issue, you will need to provide us with appropriate documentation, and the system may record the communication between you and the customer service so that we can better assist you in resolving the issue you are inquiring about and improve the quality of customer service. If you do not provide the above information, we may not be able to provide you with timely feedback on the results of your inquiry, but it will not affect your normal use of one2free account services.

1.2 In order to provide you with a better one2free account service, we may need to collect the following information. If you refuse to provide the following information, it will not affect your normal use of the basic business functions under Article 1.1, but you may not be able to obtain the user experience that these extended business functions bring to you. These expanded business features include:

· Complete your account information:

During your registration, login or subsequent use, you can fill in additional basic personal information on your own: such as your nickname, avatar, we will conduct user and market research analysis based on the information you fill in (such as judging your approximate user attributes) to improve and improve our product design and provide you with a better service experience. This is unnecessary information for using one2free account services. You can also choose not to fill in the other basic personal information mentioned above. If you do not fill it out, it will not affect your normal use of one2free account services.

2. Personal information we voluntarily collect in the course of providing our services to you

Subject to laws and regulations, in order to ensure the security of your account and better provide you with quality services, we will collect and use the following information generated during your use of one2free account services. The relevant functional scenarios are as follows:

2.1 Troubleshooting and Security Maintenance

When you use the one2free account service, we will follow the minimum necessary principles to receive and record your relevant device information and network logs to determine whether the current registration and login environment is secure and troubleshoot problems. The necessary information includes your registration/login time, device-related information (such as the device ID (Android mobile device Android ID, smart hardware device identification SN), device model, operating system version), and network information (such as the usual login IP address). This is necessary information for troubleshooting and security maintenance. If you refuse to collect the above information, we will not be able to monitor and maintain the security of your account, which may affect the safety of your account and the timely troubleshooting of related issues.

2.2 Operational Statistics and Analysis

We may also collect other information that does not accurately identify a specific individual, such as user account behavior record information when you use one2free account services, so that we can count the use of one2free accounts, ensure the stability of the service, and analyze business and service, improve and optimize the product interaction experience through data statistics. Relevant and necessary information includes logon/logout records, interaction records, error records, and statistical data generated when using specific services. This information is necessary for operational statistics and analysis. If you refuse to collect the above information, we will not be able to troubleshoot and operate statistics for your account, which may affect the safety and experience of your account.

III. How We Entrust Processing, Sharing, Transferring, and Publicly Disclosing Your Personal Information

1. Delegated processing

In order to provide you with better and better products and services, we may entrust third parties (including companies, organizations and individuals) to process some of your personal information. We will sign a strict data processing agreement with the third party with whom we entrust the processing of your personal information, clearly stipulating the purpose, period, processing method, type of personal information, protection measures, rights and obligations of both parties, etc., and supervise the personal information processing activities of the third party, requiring the third party to process your personal information only in accordance with our requirements, the provisions of this policy, and any other relevant confidentiality and security measures, and not to process personal information beyond the agreed processing purpose and processing method. If you refuse a third party to collect personal information necessary to provide the service when providing the service, you may not be able to use the service provided by the third party in the process of using the one2free account service.

2. Share

We do not share your personal information with third parties, including companies, organizations, and individuals, except:

(1) Sharing with explicit consent: After obtaining your individual, explicit consent, we will share your personal information with other parties.

(2) Sharing under statutory circumstances: We may share your personal information externally in accordance with laws and regulations, litigation and dispute resolution needs, or in accordance with the requirements of administrative and judicial organs according to law.

(3) Sharing with Authorized Partners: For the purposes stated in this policy only, some of our services will be provided jointly by us and the Authorized Partner. We may share some of your personal information with our partners to provide better customer service and user experience. We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and only the personal information necessary to provide the Services. Our partners do not have the right to use the personal information they share for any other purpose.

We enter into strict confidentiality agreements with companies, organizations, and individuals with whom we share personal information, requiring them to process personal information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures, and to ensure that their processing does not violate relevant laws, regulations, and regulatory requirements relating to the protection of personal information and data security, national standards, and other regulatory documents. In principle, companies, organizations, and individuals with whom we share personal information do not have the right to use the personal information we share for any purpose other than this Policy.

3. Assignment

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

(1) Assignment with express consent;

(2) The transfer is made in accordance with applicable laws and regulations, the requirements of legal procedures, and mandatory administrative or judicial requirements;

(3) In the event of a merger, acquisition or bankruptcy liquidation of the Service Provider, or other circumstances involving 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 policy, otherwise we will require the company, organization or individual to seek your authorization and consent again.

4. Public Disclosure

We will only publicly disclose your personal information if:

(1) We may publicly disclose your personal information with your individual consent or based on your active choice;

(2) We may disclose your personal information publicly where required by law, legal process, litigation, or mandatory by government authorities;

(3) If we determine that you have violated laws and regulations or seriously violated the rules of this service related agreement, or in order to protect the personal and property safety of users or the public of the service and its affiliates, we may disclose personal information about you in accordance with laws and regulations or the rules of this service related agreement, including relevant violations and the measures taken against you by this service;

(4) In case of emergency, in order to protect the legitimate rights and interests of you, the company and other users or public safety and interests.

5. Exceptions to obtaining prior authorization and consent when sharing, transferring, or publicly disclosing personal information

In the following cases, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization.

(1) It is related to our performance of obligations under laws and regulations;

(2) directly related to national security and national defense security;

(3) Those directly related to public safety, public health, and major public interests;

Situations that directly concern criminal investigation, prosecution, judgment and execution of sentences;

(5) It is difficult to obtain my consent for the purpose of safeguarding your or other individuals' lives, property and other major legitimate rights and interests;

(6) Personal information that you disclose to the public on your own;

(7) Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

(8) Other circumstances stipulated by laws and administrative regulations.

Please note that according to the law, the sharing and transfer of anonymized personal information is not an act of external sharing, transfer and public disclosure of personal information, and the storage and processing of such data will not need to notify you separately and obtain your consent.

IV. How we protect your personal information

1. We attach great importance to users' privacy and personal information protection, and will also take reasonable measures to protect users' personal information. Unless otherwise stipulated by laws and regulations or this policy, we will use various security technologies and procedures to establish a sound management system to protect your personal information from unauthorized access, use or disclosure. Without the user's permission, we will not disclose or disclose the user's personal information to third parties, and will use professional encrypted storage and transmission methods to protect the security of the user's personal information.

2. You understand and agree that under the premise of not disclosing the privacy information of a single user, we have the right to carry out technical analysis on the entire user database. Only the user data that has been anonymized after analysis and collation can be used commercially.

3. Data security measures

(1) We have adopted security measures that comply with industry standards, including establishing reasonable institutional norms and security technologies to prevent unauthorized access, use, and modification of your personal information, and to avoid data damage or loss. For example, our network services utilize encryption technologies such as Transport Layer Security (TLS) and Secure Sockets Layer (SSL), and provide browsing services through methods such as https, ensuring the security of user data during transmission. We employ encryption technologies (TLS, SSL), anonymization processing, and protection mechanisms to encrypt and store user personal information, and isolate it through isolation technologies. We manage and regulate the storage and use of personal information by establishing data classification and grading systems, data security management norms, and data security development specifications. We only allow employees and partners of Lita Digital Co., Ltd. who have a need to know such information to access personal information through confidentiality agreements with information contacts, and have set up strict access control and monitoring mechanisms for this purpose. At the same time, we require all personnel who come into contact with your personal information to fulfill corresponding confidentiality obligations. Failure to fulfill these obligations will result in legal liability or termination of our partnership. We have held security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information. We have formulated and implemented emergency response plans for personal information security incidents, among others.

(2) We have taken all reasonably practicable measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for as long as is necessary to achieve the purposes described in this policy, unless an extension of the retention period is required or permitted by law.

(3) The Internet is not an absolutely secure environment, and e-mail, instant messaging, and communication with other users are not encrypted, and we strongly recommend that you do not send personal information through such means. Please use a strong password to help us keep your account secure.

(4) The Internet environment is not 100% secure and we will do our best to ensure or guarantee the security of any information you send to us. We will be liable if our physical, technical, or administrative safeguards are compromised, resulting in unauthorized access, public disclosure, alteration, or destruction of information to the detriment of your legitimate interests.

(5) After an unfortunate personal information security incident occurs, we will promptly inform you of the cause of the security incident, the possible hazards, the types of personal information involved, the disposal measures we have taken or will take, and the suggestions and possible measures you can take to prevent and reduce risks on your own. We will promptly inform you about the incident by email, text message, phone call, push notification, etc. When it is difficult to inform the personal data subject one by one, we will use reasonable and effective methods to issue an announcement. At the same time, we will also take the initiative to report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities. Please be aware that we may process your personal information under certain circumstances in accordance with applicable laws and regulations that do not require notification.

V. How WE store your personal information

1. Where the information is stored

In principle, the personal information we collect and generate for the Service will be stored in the cloud of our partners and will not be transferred to other regions. Exceptions:

It is clearly stipulated in laws and regulations;

with your express authorization;

You conduct cross-border transactions and other personal proactive behaviors through the network.

2. Duration of storage of information

In general, we will retain your personal information for as long as necessary to achieve the purposes described in this policy while you are using one2free account services, unless otherwise specified by applicable laws and regulations or national regulatory documents. After the above deadline, or if you voluntarily request the deletion of your personal information or the deletion of your account, we will delete your personal information as soon as is required by applicable laws and regulations, unless the applicable laws and regulations or national regulatory documents require that such information be retained for a longer period of time. However, in the following circumstances, the British Virgin Islands Lita Digital Co., Ltd. Due to the need to comply with legal requirements, change the storage time of personal information:

· To comply with applicable laws and regulations;

· To comply with a court decision, ruling or other legal process;

· To comply with the requirements of the relevant governmental authority or legally authorized organization;

· We have reason to believe that we need to comply with relevant provisions such as laws and regulations;

· Use that is reasonably necessary to protect the personal and property safety or other legitimate interests of one2free's customers, one2free, other users or employees in order to implement the relevant service agreement or this policy and to safeguard the public interest of society.

After you terminate your one2free account, we will stop collecting and using your information, unless otherwise required by laws and regulations or regulatory authorities. When the services related to one2free account are discontinued, we will notify you in the form of push notifications and announcements, and delete your personal information retained on the server within a reasonable period of time.

VI. how you realize your right TO manage your personal information

In accordance with the relevant laws, regulations and standards, you have a number of rights in the processing of personal information, including:

· You have the right to know and decide on the processing of personal information, and the right to restrict or refuse others to process your personal information, except as otherwise provided by laws and administrative regulations;

· You have the right to consult and copy your personal information from the personal information processor, unless otherwise provided by law;

· You have the right to request the transfer of your personal information to a personal information processor designated by you;

· If you find that your personal information is inaccurate or incomplete, you have the right to request the personal information processor to correct or supplement it;

· You have the right to request the deletion of your personal information;

· You have the right to request the personal information processor to explain its personal information processing rules.

We guarantee that you exercise the aforementioned rights over your personal information and provide you with the relevant operation path, specifically, you can refer to the following steps to do so:

1. Control settings

(1) You can manage/set (view and change) your account security information, personal information, and device/app management information in the one2free account center on the page of the product or service you use. Please be aware that the content displayed on the one2free account center page may vary depending on the specific product or service you use;

(2) You can choose to log in or log out of your one2free account.

2. Access, Correction, Supplement, Deletion

You have the right to access, correct, supplement, and delete your personal information, with exceptions provided by laws and regulations. For more details related to the personal information in your one2free account, you can log in to your one2free account through your device or app, view your account information and other relevant information under your account, change your password/nickname/avatar (you will need to verify your identity when updating your password) on the device or app settings page.

3. Get a copy of your account info

You have the right to a copy of your account information, you can contact our customer service as described in section 9 of this policy, and we will process your request within 15 business days.

4. Transferring your personal information

You have the right to request the transfer of your personal information to the personal information processor designated by you. If the conditions stipulated by the national network information department are met, we will provide you with a way to transfer it. You can contact our customer service as described in section 9 of this policy and we will process your request within 15 business days.

VII. How WE protect minors' personal information

1. We attach great importance to the protection of the personal information of minors, and we will protect the personal information of minors in accordance with the provisions of applicable relevant laws and regulations.

2. We treat anyone under the age of 18 as a minor. According to the relevant laws and regulations, if you are a minor over the age of 14, we will obtain your or your guardian's consent before collecting your personal information, and when you, your parents or other guardians request us to correct or delete the minor's personal information, we will take timely measures to correct or delete it, except as otherwise provided by applicable laws and administrative regulations.

3. If you are a minor under the age of 14 (hereinafter referred to as a child), we will obtain your parent's or other guardian's consent before collecting your personal information.

4. When processing children's personal information, we will take the following measures to protect it: In addition to complying with the provisions of this policy on users' personal information, we will also adhere to the principles of legitimate necessity, informed consent, clear purpose, security, and legal use, and strictly comply with the requirements of laws and regulations such as the "Provisions on the Protection of Children's Personal Information Network" for storage, use, and disclosure, and will not exceed the period necessary to achieve the purpose of collection and use. After the expiration of this period, we will delete children's personal information. To learn more, read the Children's Privacy Policy for the product or service you use.

5. If you are a parent or guardian of a minor, if you have any questions, comments, suggestions or complaints, or reporting needs related to this policy and the Children's Privacy Protection Policy, please contact us through the method described in Chapter 11.

8. How your personal information is transferred globally

8.1 We will take the following measures to protect the security of personal information transferred across borders:

In accordance with the relevant laws, regulations and supervision regulations, we guarantee that you will exercise the following benefits with respect to your personal information: 6.1 Access, correction and update of your personal information You have the right to review, correct and update your personal information through our official website, mobile app and other channels, unless otherwise provided by laws and regulations. You have the right to keep your personal information up to date.

· Deleting your personal information

You can request deletion of your personal information from us in the following situations:

If we process personal information in violation of laws and regulations:

if we collect and use your personal chiropractic communications without your consent;

if our processing of personal information violates our agreement with you;

Other circumstances stipulated by laws and administrative regulations.

· Control the deregistration of personal information accounts by logging out of the account. Contact customer service directly to cancel the account. After deleting the account, we will delete or anonymize the user's personal information; 6.4 You have the right to ask our personnel to explain the personal information processing rules through the contact information described in Article 7 of this Privacy Policy. 6.5 Respond to your above request

For your safety, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. Please understand that we may decline certain requests that are unreasonably repetitive, require excessive technical means, pose a risk to the legitimate interests of others, or are highly impractical.

Notwithstanding the foregoing, as required by laws and regulations, we may not be able to respond to your request if:

Related to national security and national defense security;

It is in line with public safety, public health, and major public interests;

Related to criminal investigations, prosecutions, trials and sentencing:

There is sufficient evidence of subjective malice or abuse of power on your part;

Responding to your request will cause serious damage to the legitimate interests of you or other individuals or organizations;

Dumplings are bigger than our trade secrets.

IX. How WE update this policy

1. In order to provide you with better service, the one2free account service will be updated and changed from time to time. We will revise this policy from time to time, and these revisions form part of this policy. However, we will not diminish your rights under this policy without your explicit consent.

2. After this policy is updated, we will issue an updated version in the relevant product, and remind you to read the updated privacy policy again through the new version feature announcement or pop-up window, so that you can keep abreast of the latest version of this policy. If you do not agree with this Policy, or if you disagree with any changes or updates to this Policy, you may choose to stop using the relevant products and/or services or cancel your account. However, please be aware that your actions and activities prior to the deactivation of your account and prior to the discontinuation of your use of the Service are still governed by this Policy.

3. For material changes, we will also provide more prominent notices (we will explain specific changes to this policy, including but not limited to emails, text messages, or special reminders on browsing pages).

Significant changes to this policy include, but are not limited to:

(1) There has been a significant change in our service model. Such as the purpose of processing personal information, the type of personal information processed, how personal information is used, etc.;

(2) We have undergone significant changes in our ownership structure, organizational structure, etc. such as all changes caused by business adjustments, bankruptcy mergers and acquisitions, etc.;

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

(4) There has been a significant change in your right to participate in the processing of personal information and the manner in which you exercise it;

(5) When the department responsible for handling personal information security, contact information and complaint channels change;

(6) When the personal information security impact assessment report indicates that there is a high risk;

(7) With the issuance and implementation of policies or laws, changes are made in response to national policies or legal norms.

4. We encourage you to review this policy while using our services. Specifically, you can consult the privacy policy of the product or service you use and review this policy by clicking on the link to the one2free Account Privacy Policy in the privacy policy or otherwise.

X. How to contact us

To better protect your personal information, we have a dedicated cybersecurity and personal information protection department. If you have any questions or suggestions about this policy or your personal information while using your one2free account, please contact us at:

Email address: [service@litok.ai]

If you are dissatisfied with our response, especially if you believe that our processing of personal information harms your legitimate rights and interests, and we are unable to provide a satisfactory response after you have given us feedback and refuse to improve, you can file a complaint and report it to the relevant regulatory authority.

11. Miscellaneous

Any dispute related to this policy shall be settled through friendly negotiation between the two parties; if it cannot be settled through negotiation, you hereby agree to file a lawsuit with the people's court of the local government.

If any court of competent jurisdiction rules or decides that any provision of this Policy is invalid, that provision will be removed from this Policy, but the invalidity of that provision shall not affect the validity of the remaining provisions of this Policy. The remaining provisions of this policy will continue to be enforced.