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OtterLife Privacy Policy

Effective Date: November 22, 2023 Updated Date: January 22, 2026 Preface This “OtterLife Privacy Policy” (hereinafter referred to as “this Privacy Policy” or “this Policy”, this Privacy Policy together with its updated versions collectively constitute “this Privacy Policy”) applies to products and services provided by OtterLife product service provider [Shanghai Ruoyou Network Technology Co., Ltd.] (hereinafter referred to as “OtterLife Operator” or “we”) to users (also referred to as “you”). This Privacy Policy will detail the policies and measures of OtterLife Operator in obtaining, managing, and protecting your personal information. Part One: Definitions Personal information refers to various information recorded electronically or by other means that can identify a specific natural person’s identity or reflect a specific natural person’s activities, either alone or in combination with other information. Sensitive personal information refers to personal information that, once leaked, illegally provided, or misused, may endanger personal and property safety, and is highly likely to cause damage to personal reputation, physical and mental health, or discriminatory treatment. Part Two: Personal Information Privacy Policy

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I. How We Collect and Use Your Personal Information

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1. Accessing the Software

When you use our products and/or services, scenarios where we need/may need to collect and use your personal information include: (1) To provide you with the basic functions of our products/services, you must authorize us to collect and use necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services normally; (2) To provide you with extended functions of our products and/or services, you may choose to authorize us to collect and use information. If you refuse to provide it, you will not be able to use related extended functions normally or achieve the intended functional effects, but this will not affect your normal use of the basic functions of our products and/or services. You understand and agree:
  1. We are committed to creating diverse products and services to meet your needs. Because we provide you with a wide variety of products and services, and different users choose to use different specific products/services, the types and scope of personal information collected and used by different functions will vary accordingly. Please refer to the specific product/service functions.
  2. To bring you a better product and service experience, we are continuously improving our technology. As a result, we may launch new or optimized functions from time to time, which may require the collection and use of new personal information or changes to the purpose or method of personal information use. For this, we will separately explain to you the purpose, scope, and method of collecting corresponding information through updating this policy, pop-ups, page prompts, announcements, and other methods, and collect and use it after obtaining your consent.
When providing services, we will collect and use your personal information based on the principles of legitimacy, legality, transparency, and minimum necessity, and based on the purposes of this policy.

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(I) Basic Function Services

The basic function services we provide include: food query, viewing weight loss stories and popular science articles. We need to collect your device information, specifically including device name, device model, device identification code (including IDFA, Android_ID, MAC, OAID, Advertising ID, Serial Number, UAID, ICCID, hardware serial number UUID, IDFA), hardware serial number, device serial number, mobile application list, operating system and application version, language settings, unique device identifier, self-startup, carrier network type, and similar hardware and software characteristic information, and network information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services normally.

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(II) Extended Function Services

The main extended function services we provide include: registration and login, creating health profiles, using recording tools, exercise data synchronization, and member information synchronization, as detailed below. To provide you with better products and services, when you use extended function services, we may collect the following information. If you refuse to provide it, you will not be able to use related extended function services normally or achieve the intended functional effects.
  1. Account Registration and Login
1.1 When you register and log in to the OtterLife App, you can create an account through your phone number, and you can complete relevant personal information (including avatar, nickname, password). Collecting this information is to help you complete registration and login. If you do not provide the above information, you will not be able to complete registration and login to your OtterLife account through your phone number. 1.2 If you use a third-party account (including WeChat, QQ, AppleID) to register and log in, you need to authorize us to obtain public information registered on the third-party platform (avatar, nickname), which is used to bind with your OtterLife account so that you can directly log in and use this product and related services. If not authorized, you will not be able to complete registration and login to your OtterLife account through a third-party account. If you are not logged in, you will not be able to use the extended function services of OtterLife.
  1. Creating Health Profile
You need to complete the creation of your health profile by filling out a beginner assessment. You need to provide your basic information. Collecting this type of information is to provide you with health plans and health advice. If you cannot provide this type of information, you will not be able to create a health profile and will not be able to use the recording tools and health tool functions normally, but this will not affect your use of other functions of OtterLife.
  1. Using Recording Tools
When you need to use recording tools, you can actively choose to record your weight data, water intake data, body measurement data, diet data, exercise data, sleep data, and energy data. Collecting this information is to help you understand your body changes, and we will also provide you with relevant suggestions based on some of the data you record. If you do not provide this, you will not be able to use the recording tools. If you cannot provide the above information, you will not be able to use the corresponding tools, but this will not affect your use of other functions of OtterLife.
  1. Account Security and System Operation Security
During your use of our services, in order to understand product compatibility, protect your account security and system operation security, judge your account risk, ensure we provide you with normal services, and collect and troubleshoot abnormal information, we will collect information about the services you use and how you use them, including your use of recording tool-related functions, purchasing products and services, joining and using OtterLife platform membership. This type of information includes: 4.1 Device Information: We will receive and record device information about the device you use based on the specific permissions you grant during software installation and use. Device information includes device name, device model, device identification code (including IDFA, Android_ID, MAC, OAID, Advertising ID, Serial Number, UAID, ICCID, hardware serial number UUID, IDFA), mobile application list, operating system and application version, language settings, unique device identifier, carrier network type, and similar hardware and software characteristic information. If you refuse to provide device information, you may not be able to use our services normally. 4.2 Log Information: Configuration information provided by device or software information (including your mobile device, web browser, or other programs used to access our services), your IP address and version used by your mobile device and device identification code (including IDFA, IDFV, IMEI, AndroidID, OAID, IMSI, ICCID, GAID, MEID, AAID, VAID), information searched or browsed when using our services (including web search terms you use, URLs of social media pages visited, and other information and content details you browse or request when using our services). To provide you with better service and user experience, we may use your collected operation/usage records (including browsing, searching, clicking), purchase records, information you actively provide (evaluations, feedback), log information, IP address, location information, device information (including device model, operating system version, device settings, device environment, MAC address, IDFA, OAID device identifier, mobile application list, telecom carrier hardware and software characteristic information). We guarantee that without your authorization and consent, we will not provide your information to any third party.
  1. Exercise Data Synchronization
With full notification of the body data and exercise data types synchronized from third-party software (including Apple Health, Huawei Health) to OtterLife and your authorization, we will obtain your body data and exercise data generated in the third-party software and synchronize it to your OtterLife account. After you authorize the association of third-party software data, OtterLife will automatically synchronize your aforementioned data from the corresponding third-party software. Collecting this type of information is to simplify your recording process and better serve you. If you do not agree to data association, you can cancel synchronization in [Me] - [Settings] - [Data Sync Settings]. After you cancel synchronization, we will no longer collect relevant information and will not be able to provide you with corresponding services; however, unless you delete your information in accordance with legal provisions, your cancellation will not affect the storage or processing of information based on your previous authorization.
  1. Media Library Monitoring Permission
When you take a screenshot in the App (Android), we will detect the generation of new multimedia files such as images and audio in the local album, thereby automatically triggering the sharing function, allowing you to use that multimedia file directly for sharing, eliminating the step of entering the album to select multimedia files for sharing.
  1. Application Self-startup
android.intent.action.BOOT_COMPLETED: This application has a certain frequency of self-startup or associated startup behavior through system broadcast, which is necessary for the timely update function of health data.

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2. Using OtterLife Services

  • Client hardware characteristic information: device model, device sensors, device hardware serial number, operating system version, battery, signal strength information;
  • Software characteristic information: software version number, browser type;
  • Service log information: information you view when using our services, service failure information, and other similar service log information;
  • Other log and device information:
In addition to the above information, other log and device-related information we may collect mainly includes: IMEI, MAC, SIM card IMSI identification code, device settings, process and software list, unique device identifier. To help you better use our products or services, we may also collect relevant information in addition to the information listed above: (1) We may collect anonymized information for research, statistical analysis, and prediction (including using anonymous data for machine learning, model algorithm training, etc.) to improve products and make commercial decisions; (2) When you contact us, we may record your conversation with us and collect other necessary information to verify your identity and resolve issues. In any case, when collecting the above information, we will still follow the principles of “minimum limit” and “necessity,” and will do well in protecting relevant data in accordance with regulations. Please be fully aware that in the following circumstances, we do not need to (re)obtain your authorization and consent to collect and use personal information: (1) Related to national security and national defense security; (2) Related to public safety, public health, and major public interests; (3) Related to criminal investigation, prosecution, trial, and judgment execution; (4) To protect the life, property, and other major legitimate rights and interests of the personal information subject or other individuals but it is difficult to obtain the individual’s consent; (5) Personal information that the personal information subject has disclosed to the public on their own; (6) Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure, and other channels; (7) Necessary for signing and performing a contract at your request; (8) Necessary for maintaining the safe and stable operation of the services provided, including discovering and handling service failures or similar situations; (9) Other circumstances stipulated by laws and regulations.

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5. Accessibility Service API License Disclosure Statement

OtterLife may use the Accessibility API service to help you quickly translate non-native language text in applications to achieve multilingual accessibility. If you do not grant this permission, it will not affect the normal use of other functions.

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Health and Fitness Information

We request to be associated with Apple Health & Google Health Connect to obtain your step count data, sleep analysis, heart rate, and establish your calorie consumption goals. Important: Generally, your health data is stored and utilized locally on your device. It is not uploaded to our servers for general storage. However, if you explicitly choose to use our AI-powered features, specific health metrics necessary for the analysis will be temporarily transmitted to our AI service provider. (See “AI-Powered Features and Data Processing” section below).

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AI-Powered Features and Data Processing

OtterLife includes optional features powered by artificial intelligence to provide you with personalized health insights and recommendations. Data Sharing: When you use these features, we transmit relevant data (such as your activity logs, sleep patterns, or user queries) to our trusted third-party AI service providers solely for the purpose of generating a response. AI Service Provider: Our current AI service provider is Google Gemini, provided by Google. User Consent: We will always ask for your explicit permission within the app before sending any personal health data to the AI service. Data Protection: We have entered into agreements with our AI providers ensuring that your health data is NOT used to train their AI models and is not retained by them after the analysis is complete.

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How We Use Information

We use the information we collect for the following purposes: Improve, Personalize, and Develop the Services We utilize collected information to enhance, personalize, and develop OtterLife services. This includes generating AI-based health advice, ensuring service stability, and developing new features. Processing health data is based on your consent (GDPR, Art 6.1(a) and Art 9.2(a)). Communicate With You We use your information to send you service notifications and respond to your inquiries. We assure you that the information we collect will never be sold.

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Sharing of Information

We do not sell your personal data. We may share information in the following limited circumstances: AI Service Providers: To provide intelligent health analysis features (as detailed in the “AI-Powered Features and Data Processing” section). Legal Requirements: We may disclose information about you to comply with legal obligations, protect our rights, or prevent illegal activity. Aggregated Data: We may share non-personal information that is aggregated or de-identified to prevent identification of individuals.

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Security of Your Personal Data

We prioritize the security of your personal data and implement a range of technical and organizational measures to protect it. Our security measures include: Data Encryption: Encrypting personal data both in transit (including data sent to AI providers) and at rest. System Security Checks: Regularly conducting system vulnerability scans and penetration tests. Access Control: Only personnel responsible for data management can access your personal data. Data Anonymization: Anonymizing and tokenizing certain categories of personal data where possible.

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

When performing relevant sharing, transfer, and public disclosure actions, we will only share, transfer, and publicly disclose necessary personal information, and are bound by the purposes stated in this policy. (I) Use and Provision of Personal Information Without your consent, OtterLife Operator will not share your personal information with any company, organization, or individual other than itself, except in the following circumstances:
  1. Sharing with explicit authorization and consent: Authorization or consent has been obtained from you or your guardian. Such as providing at your request to handle disputes or controversies between you and others or in accordance with the relevant agreements signed with you (including the “OtterLife Software License and Service Agreement”) or other legal documents;
  2. Sharing under legal circumstances: According to relevant laws and regulations, for the needs of litigation activities, or to satisfy disclosure requirements based on legal procedures by judicial or administrative authorities. For example: within the scope permitted by laws and regulations, when it is necessary to protect the interests, property, and safety of OtterLife or OtterLife’s partners, you, other OtterLife users, or the public from harm;
  3. Sharing with OtterLife Operator’s affiliates: To provide you with services, or to protect the personal and property safety of you or OtterLife Operator’s affiliates or other users from infringement, OtterLife Operator may share your personal information with its affiliates;
  4. Sharing with OtterLife Operator’s authorized partners: We will entrust authorized partners to provide you with certain services or perform certain functions on our behalf. To protect the security of your personal information, before sharing your personal information with partners, we will sign corresponding personal information use or confidentiality agreements with them, requiring them to process personal information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures.
For more information, please refer to the Third-Party SDK List (II) Transfer We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:
  1. With your explicit consent;
  2. When involving merger, acquisition, or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this policy, otherwise we will require that company or organization to re-seek your authorization and consent;
  3. In accordance with the relevant agreements signed with you (including electronically signed online agreements) or other legal documents;
  4. When necessary according to applicable laws and regulations, legal procedures, or mandatory administrative or judicial requirements.
(III) Public Disclosure We will only publicly disclose your personal information in the following circumstances:
  1. With your explicit consent or based on your active choice;
  2. Disclosure based on laws and regulations: In the case of mandatory requirements by law, legal procedures, litigation, or government authorities, we may disclose your personal information.
(IV) Sharing, Transfer, and Public Disclosure Without Prior Authorization and Consent Based on relevant laws and regulations, in the following circumstances, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent:
  1. Related to national security and national defense security;
  2. Related to public safety, public health, and major public interests;
  3. Related to criminal investigation, prosecution, trial, and judgment execution;
  4. To protect the life, property, and other major legitimate rights and interests of you or other individuals but it is difficult to obtain the individual’s consent;
  5. Personal information that you have disclosed to the public on your own;
  6. Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure, and other channels.
According to laws and regulations, sharing and transferring de-identified personal information, and ensuring that the data recipient cannot restore and re-identify the personal information subject, does not constitute external sharing, transfer, and public disclosure of personal information. The storage and processing of such data will not require separate notification and consent from you.

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III. How We Protect and Store Your Personal Information

(I) Protection of Personal Information
  1. OtterLife Operator will conduct level assessment and security evaluation of OtterLife in accordance with relevant regulations.
  2. We will take reasonable and feasible measures to try to avoid collecting irrelevant personal information. We will store personal information collected and generated within the People’s Republic of China within the territory of the People’s Republic of China.
  3. OtterLife Operator has strict data protection and management measures. We will take security measures to protect your personal information from unauthorized access, use, disclosure, modification, damage, loss, and other forms of illegal processing.
  4. In the unfortunate event that the data security obtained and stored by OtterLife Operator is compromised, or due to external actions (such as hacker attacks) the user’s non-public information is disclosed to unrelated third parties, OtterLife Operator will activate emergency plans, form an emergency response team, start procedures, conduct internal investigations, report to and notify regulatory authorities, and cooperate with regulatory authorities to reduce the impact of the incident on users. At the same time, we will inform relevant users through push notifications, emails, announcements, and other forms.
  5. If our products or services cease operations, we will promptly stop collecting your personal information and notify you of the cessation through push notifications, announcements, and other forms. In any case, we will delete or anonymize your personal information held by us after terminating services or operations.
(II) Storage of Personal Information OtterLife Operator will take appropriate security measures and technical means to store and protect your personal information to prevent loss, misuse, unauthorized access or disclosure, alteration, or destruction. We only store personal information for the period necessary to achieve the purposes of this privacy policy according to the storage period corresponding to different levels of personal information, and the storage period strictly complies with laws and relevant regulations. According to the provisions of this clause, we only allow employees and other third parties who need to know this information to access personal information and require them to fulfill corresponding confidentiality obligations.

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IV. How You Access and Control Your Personal Information

  1. Changing or Withdrawing Authorization
You can set and modify the device permissions that allow the OtterLife client to access through your device’s permission settings. After the relevant settings and modifications take effect, OtterLife Operator will not be able to provide you with corresponding services. Your withdrawal or change of your authorization will not affect the collection and use of personal information based on your previous authorization. (1) Turning off notifications: If you do not wish to receive notifications from OtterLife, you can turn off the “Notification” function through system settings on your device;
  1. Account Cancellation
You can request account deletion by going to Settings - About You - top right button, or by sending an email to otterlife@iftech.io with a screenshot of your user profile. After requesting deletion, we will process it within 7 business days. If you log in again during this period, the deletion request will be automatically cancelled.
  1. Stop Using Services
Except for notification and album functions and location functions, other information collected by OtterLife is necessary for the basic operation of OtterLife. If you stop using our services, we will delete or anonymize the information collected to provide you with services; for information that needs to be retained for a certain period due to special circumstances as required by laws and regulations, we will no longer use it in daily business activities and take reasonable and appropriate measures for protection.

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V. How We Handle Minors’ Personal Information

Minors should obtain the consent of their guardians before using our products or services. If you are a minor under the age of eighteen, before using our products or services, please have your parents or guardians carefully read this privacy policy, and use our products or services or provide us with information with the consent of your parents or guardians. When OtterLife Operator requires you to assume responsibility according to legal provisions or this agreement, we have the right to seek recourse from your guardian. If you are the parent or guardian of a minor, you should carefully read all the contents of this agreement before agreeing to let the minor use our products or services. Note: If you are the parent or guardian of a minor, you should carefully read all the contents of this privacy policy before agreeing to let the minor use our products or services. If you have any questions, you can contact us through the contact information disclosed in this privacy policy. If you use OtterLife, we will assume that you have obtained the aforementioned consent. We will protect the personal information of minors in accordance with relevant national laws and regulations and this privacy policy.

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VI. How Your Personal Information Is Transferred Globally

OtterLife Operator will store personal information collected and generated during operations within the People’s Republic of China within the territory of China, except in the following circumstances:
  1. Where applicable laws clearly stipulate;
  2. With your explicit authorization;
  3. Personal active actions you take through the internet.
For the above circumstances, OtterLife Operator will ensure sufficient protection of your personal information in accordance with this privacy policy.

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VII. How This Policy Is Updated

Due to factors such as product form changes and revisions to laws and regulations, we may revise this policy from time to time. At the same time, we will publish any changes to this policy on this page. If you have objections to the revised privacy policy, you should stop using our related services in time. If you agree to the newly revised policy or continue to use our services, it means that you have fully read, understood, and agreed to our policy.

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VIII. How to Contact Us

If you have any questions, comments, or suggestions about this privacy policy, you can send the relevant content to: OtterLife@iftech.io After we receive your question, we will verify your identity and process your feedback question and reply to you in a timely manner. If you are not satisfied with our reply, especially if you believe that our personal information processing methods have damaged your legitimate rights and interests, you can also seek solutions by filing a lawsuit with a court with jurisdiction in Yangpu District, Shanghai. Special notes:
  • OtterLife products refer to the mobile client application labeled “OtterLife.”
  • OtterLife Operator refers to Shanghai Ruoyou Network Technology Co., Ltd.
Before using the services provided by OtterLife Operator, please be sure to carefully read and understand this privacy policy (especially the bold clauses), understand in detail how we collect and use information, and independently choose whether to agree to the relevant content. Selecting “Agree” or performing “Next Step” (or performing other similar operations with different names but the same nature) indicates that you have fully understood and agreed to sign this agreement, promising to accept the binding of the agreement as a party to the agreement, and agree that OtterLife Operator will process your personal information in accordance with this privacy policy. If you have any objections to any terms of this agreement, or cannot accurately understand any terms of this agreement, please do not access and/or use the OtterLife application and its related services. Minors under the age of eighteen should read this policy under the supervision of a guardian and may only use OtterLife services after obtaining their consent to your use of the services and all terms of this agreement. If you have any comments, suggestions, or questions about this privacy policy, you can contact us through the method disclosed in this privacy policy (send relevant content to: OtterLife@iftech.io) or other contact/feedback channels provided within OtterLife, and we will answer your questions as soon as possible.