INS New Paradise Privacy Policy

Version: V1.13, Updated on:November 24, 2025

New Electric Hero (Shanghai) Information Technology Co., Ltd.

and its affiliates (hereinafter referred to as "we") are dedicated to safeguarding and upholding the personal information security of users (hereinafter collectively referred to as "you" or "users"). Through the "INS New Paradise Privacy Policy" (hereinafter referred to as "this Privacy Policy"), we want to inform the users and partners of this platform about how we collect, process personal information, and inform you of your rights. 

We understand the importance of handling personal information to you and strictly comply with relevant legal regulations. Protecting your personal information is crucial for us, users, and partners. We promise that the processing of your personal information complies with the "Civil Code of the People's Republic of China," the "Cybersecurity Law of the People's Republic of China," GB/T 35273-2020 "Information Security Technology Personal Information Security Specification," and other applicable data protection rules.

This Privacy Policy may be supplemented by other privacy statements, terms, agreements, or notices provided to you.

Article 1: Basic Principles of Data Processing

We handle your personal information strictly in accordance with applicable laws and the following basic principles: the principle of openness and transparency, the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of minimum necessity, the principle of choice consent, the principle of ensuring security, the principle of subject participation.

Article 2: Personal Information Collection

"Individual" refers to registered users of INS New Paradise Park.

"Personal information" refers to various information recorded electronically or in other ways that can identify the identity of a specific natural person alone or in combination with other information or reflect the activities of a specific natural person, such as: name, date of birth, ID number, personal biometric information, address, contact information, communication records and content, account password, property information, credit information, travel trajectory, accommodation information, health and physiological information, transaction information, etc.

"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. For example, sensitive personal information includes ID numbers, personal biometric information, bank account information, communication records and content, property information, credit information, travel tracks, accommodation information, health and physiological information, transaction information, and personal information of children aged 14 and below.

Information that cannot identify a specific natural person or reflect specific natural person activities does not constitute personal information.

We will only collect and process your personal information for the purposes described in this policy.

(1) Collection Purpose

1. To provide services to registered users as a product developer or service provider;

2. To enhance the security and reliability of services.

3. Data analysis: We may use personal information for analysis in order to develop or improve our products, services, or marketing plans.

4. Legal and compliance requirements: We may need to use your information to handle and resolve legal disputes, or to comply with any laws, regulations, or documents issued by regulatory authorities that are binding on us, in order to cooperate with national departments or regulatory agencies in investigations and to comply with legal regulations.

(2) How do we collect your personal information?

1. Personal information is collected directly with your authorization during registration and use of our services.

2. Obtain your personal information under your third-party account with your authorization.

3. Collect your personal information indirectly from third parties.

4. When you file a complaint, appeal, or inquiry with us, we collect the information you provide.  

5. Other methods authorized by you legally.

(3) What types of personal information do we collect and process?

When you use our products and services, or when you authorize us to use your personal information for data processing and analysis, we may collect the following personal information about you:

1. Our product is developed based on DCloud uni-app (5+ App/Wap2App). During application runtime, in silent state, or when running in the background, we need to collect your device's unique identification code (IMEI/Android ID/DEVICE_ID/IDFA, SIM card IMSI information, OAID) to provide statistical analysis services, and improve performance and user experience through application startup data and error log analysis, in order to provide better services to users. Please visit the "DCloud User Service Agreement" for more details (link: https://ask.dcloud.net.cn/protocol.html).

2. Personal sensitive information that we collect:

3. General personal information we collect:

(4) Calling device permissions

When you use INS New Paradise services, we may need to request some of your device permissions (see the table below for details). We will obtain your consent separately through a pop-up window before the first request for the corresponding permission. You can choose to disable some or all of the permissions in the device settings function or similar functions according to the specific guidelines of your mobile operating system. If you disable these permissions, we will no longer continue to collect and use your corresponding information, and we will not be able to provide you with the functions corresponding to these permissions.

(5) Exceptions to the collection and use of personal information

In the following situations involving information collection and use, we may not need to obtain your authorization:

1. Related to our compliance with legal requirements;

2. Directly related to national security and defense.

3. Directly related to public safety, public health, and major public interests.

4. Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;

5. Necessary to protect your or others' significant legal rights and interests, such as life and property, but difficult to obtain your consent.

6. The personal information collected is voluntarily disclosed by you to the public.

7. Personal information collected from legally publicly disclosed sources, such as legitimate news reports and government information disclosure channels;

8. Necessary for signing and fulfilling a contract as per your request;

9. Necessary for maintaining the safe and stable operation of the products or services provided;

10. Other circumstances stipulated by laws and regulations.

Article 3: Sharing, Transfer, and Public Disclosure of Personal Information

We respect your personal privacy and comply with relevant laws and regulations. We promise to strictly keep your personal information confidential and will not sell your personal information to others. We may disclose relevant information and data to third parties only after confirming the personal information protection system and transmission security of the third party, and only for the purpose of fulfilling the contract, obtaining consent, or in other circumstances permitted by law.

(1) Data sharing

We will use your personal information in the following ways and share it with the following affiliated institutions or partners:

Data transfer

We will not disclose your personal information to any company, organization, or individual, except in the following circumstances:

1. Transfer with explicit consent: Upon obtaining your explicit consent, we will transfer your personal information to other parties.

2. In the event of a merger, acquisition, or bankruptcy liquidation, if there is a transfer of personal information involved, we will require the new holder of your personal information to continue to be bound by this privacy policy. Otherwise, we will require the company or organization to seek your authorization and consent again.

(3) Public disclosure

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

After obtaining your explicit consent;

2. Disclosure based on law:

3. In cases of legal, legal procedures, litigation, or mandatory requirements from government authorities, we may disclose your personal information publicly.

Article 4: Use of Cookies and Similar Technologies

(1) In order to provide you with a more relaxed browsing experience, when you use the INS New Paradise service, we may collect and store your relevant usage data through various technologies, such as cookies, flash cookies, or other local storage provided by your browser or associated applications, collectively referred to as "cookies".

When you visit or revisit INS New Paradise services, we can identify your identity and provide you with better and more services by analyzing data. Including using small data files to identify your identity, understand your usage habits, save you from repeatedly entering account information, or help determine the security of your account.

(2) Please understand that some of our services can only be accessed by using cookies. If your browser or browser add-on services allow, you can modify the acceptance level of cookies or reject INS New Paradise's cookies, but rejecting cookies may prevent you from using some features that rely on cookies in certain situations.

(3) "Web beacons" can help websites track users browsing web pages or accessing certain cookies. We will collect information about your browsing activities through web beacons, such as the page address you visited, the address of the referring page you previously visited, the time you spent on the page, your browsing environment, and display settings.

Article 5: Storage and Retention Period of Personal Information

(1) We retain your personal information for no longer than is reasonably necessary or required by law. We will largely depend on the type and purpose of the information for how long we retain it.

(2) The standards we use to establish the retention period for certain categories of data are as follows:

Has the purpose of personal information collection and processing been achieved?

Is there a contract or legal obligation that requires us to retain the data for a certain period of time?

Do you have any ongoing legal claims or matters related to your relationship with us?

Are there any applicable laws, regulations, or statutes that allow for a specific retention period?

Is the personal information considered as sensitive personal information, in which case a shorter retention period will usually be adopted.

Article 6: Protection of Minors' Data

(1) We will not directly provide products or services to individuals under the age of 18, nor will we actively collect their personal information.

(2) If we discover that our products or services have inadvertently collected data from minors without parental consent, we will take necessary measures to handle it in accordance with applicable laws as soon as possible.

Article 7: Rights of the Data Subject

(1) Right to Information

This Privacy Policy will explain to you the specific details of how we use your personal information. Furthermore, we also require our partners and other third parties to disclose the relevant usage of personal information to you in order to obtain your legal authorization.

(2) Right to Query/Access

You have the right to access the personal information we have collected. Based on legal and contractual provisions, there may be exemptions and limitations, meaning that you may not necessarily access all of the personal information we collect and process. We will notify you of any exemptions or restrictions that apply and their impact.

Before you access, we may use appropriate verification procedures to verify your identity in order to comply with data security requirements.

(3) Right to Correction

In certain situations, you have the right to request us to correct personal information that you believe is inaccurate or incomplete. We will respond to your request within a reasonable timeframe and promptly inform you of the corrected outcome or the reasons why correction is not possible.

(4) Deletion Right

In certain situations, you have the right to request the deletion of your personal information. In appropriate cases, we will comply with your request and execute it within 15 working days, notifying you of the corresponding results and reasons.

After we assist you in deleting the relevant information, due to applicable laws and security technology, we may not be able to immediately delete the corresponding information from the backup system. We will securely store your personal information and isolate it from any further processing until the backup can be cleared or anonymized.

(5) Right to Data Portability/Right to Obtain a Copy of Personal Information

You have the right to obtain a copy of the personal information you have provided to us. You also have the right to request us to transfer your personal information to another organization if you have explicitly agreed, or if it is necessary to fulfill the agreement, or if the processing is done automatically.

(6) Right to Withdraw Consent

In certain situations, you have the right to withdraw your consent. Revocation of consent does not affect the legality of processing that has been completed or is ongoing based on consent until the revocation.

(7) Close account

You can apply to close your account by following these steps.

Self-service account cancellation application: [My] - [Settings] - [Account and Security] - [Cancel Account] for application.

(8) Responding to your above request

You can submit a request for rights through the following channels:

Contact INS New Paradise customer service: Provide us with your valuable feedback through [My] - [Settings] - [Help and Feedback] - [Opinions and Feedback].

To ensure safety, you may need to provide a written request or other proof of your identity. We may first ask you to verify your identity before processing your request. We will respond within 15 business days. If you are not satisfied, you can also lodge a complaint through our official customer service phone number.

For your reasonable requests, we generally do not charge any fees. However, for multiple repeated requests that exceed reasonable limits, we will charge a certain cost depending on the situation. We may refuse requests that are unreasonably repetitive, require excessive technical means (for example, require the development of a new system or fundamentally change existing practices), pose a risk to the legitimate rights of others, or are extremely unrealistic.

In the following situations, we will be unable to respond to your request as required by laws and regulations:

1. Directly related to national security and defense security;

2. Directly related to public safety, public health, and major public interests;

3. Directly related to criminal investigation, prosecution, trial, and execution of judgment.

4. There is sufficient evidence to suggest that you are acting with subjective malice or abusing your rights.

5. Responding to your request will result in serious harm to your or other individuals' or organizations' legitimate rights and interests.

6. Involving trade secrets.

(9) Description of generative content

Users are not allowed to create, upload, copy, transmit, or spread false news information or other prohibited content using new technologies and applications such as deep learning, virtual reality, generative artificial intelligence, etc., or falsely represent synthetic content as natural content. If you publish or disseminate non-authentic information created using new technologies and applications such as deep learning, virtual reality, generative artificial intelligence, etc., you must clearly label it in a prominent manner. Otherwise, the platform has the right to take measures including but not limited to adding labels, restricting, or banning the relevant content and accounts.

Article 8: Data Security Protection Measures

We strive to provide safeguards for your information security to prevent information leakage, loss, misuse, unauthorized access, and disclosure. We employ a variety of security protection measures to ensure that your personal information is kept at a reasonable level of security, including technical safeguards, management system controls, and security system guarantees.

(1) Data transmission security: We use cryptographic technologies such as Transport Layer Security protocol and HTTPS to prevent risks of sniffing, eavesdropping, and interception of transmission links, establishing a secure environment for privacy data collection to ensure the confidentiality and integrity of data collection.

(2) Data storage security: We will store your information securely, including local storage (e.g., using the app for data caching). You can choose to delete viewing history, video cache, search records, and other data records generated while using INS New Paradise.

(3) Data access and usage security: We implement strict data access control mechanisms, adopt multi-factor authentication technologies, and monitor actions that can process your information to prevent unauthorized access and misuse of data.

(4) Establish a comprehensive audit mechanism to monitor and audit the entire data lifecycle, preventing unauthorized access, public disclosure, use, modification, or intentional or accidental damage or loss of your personal information. Other feasible security organization and management measures:

Before we collect your personal information indirectly from third parties, we will explicitly request in writing (such as cooperation agreements, commitment letters) that the party collects and processes (such as sharing) personal information only after obtaining your explicit consent. We will require the third party to commit to the legality and compliance of the source of personal information in written agreements. If the third party violates these terms, we will explicitly require them to assume corresponding legal responsibilities.

2. Before sharing your personal information with our business partners, we will strictly require our partners to fulfill their information protection obligations and responsibilities. We will also ask our business partners to sign a data security protection agreement with INS New Paradise before starting the cooperation. If any of our business partners violate the agreement, they will be held accountable for the legal consequences.

3. We have established a reasonable, effective, and scientifically sound security emergency response system, clarified the classification and grading standards for network security incidents, the security emergency response organization and its responsibilities, and formulated appropriate emergency response plans based on the different types and levels of security incidents, clearly standardizing the reporting process and emergency response handling process for security incidents. At the same time, we also have a "Security Emergency Response Center," maintained by a professional security technology and operations team, to facilitate timely and effective response and handling of various security vulnerabilities and emergencies, and to collaborate with relevant departments for security incident tracing and enforcement.

4. In the event of a personal information security incident, we will promptly inform you of the basic situation of the security incident, its possible impact, the measures we have taken or will take in accordance with legal and regulatory requirements, recommendations for you to prevent and reduce risks, and remedial measures for you. We will promptly inform you of the relevant situation of the incident via email, letter, phone, push notification, etc. When it is difficult to inform each individual personally, we will adopt reasonable and effective methods to issue a public notice.

5. Please be aware that the internet is not an absolutely secure environment. We strongly recommend using secure methods and complex passwords to help ensure the security of your account. If you discover that your personal information has been leaked, especially if your account or password has been compromised, please contact us immediately using the contact information provided at the end of this privacy policy so that we can take appropriate measures to protect the security of your personal information.

Article 9: Security Commitment of Partners

We require our partners to strictly adhere to our data protection rules and relevant data protection regulations. At the same time, they are required to obtain personal legal authorization before collecting and processing data, and to urge them to continue to fulfill this obligation. If you discover that our partners may have violated the personal information protection agreement, you can contact us for handling.

Article 10: Name and Contact Information of the Responsible Authority 

If you wish to contact us about your personal information or this privacy policy, you can reach us or the Data Protection Officer (DPO) using the following information:

New Electric Hero (Shanghai) Information Technology Co., Ltd.

Data Protection Officer (DPO):

The regular office address is: Room 402, No. 29, Yandang Road, Huangpu District, Shanghai

Phone number: 19121804905

Email: insxinleyuan@163.com

Zip Code: 200020

Article 11: Continuous Update Declaration

This privacy policy shall come into effect from the date stated at the end of this privacy policy. 

We reserve the right to modify this privacy policy at any time, so please be sure to check it frequently.

If we make significant changes to this privacy statement, we will inform you in a prominent manner through email, our website and app homepage, product device startup page, or software version updates. 

The effectiveness, interpretation, amendment, enforcement, and dispute resolution of this privacy policy are subject to the laws of the People's Republic of China. Any disputes arising from this privacy policy shall be handled in accordance with the laws of the People's Republic of China. Both parties shall first attempt to resolve the dispute through friendly negotiation. If negotiation fails, the dispute, controversy, claim, termination of contract, or invalidity of contract shall be submitted to the Shanghai International Arbitration Center for arbitration in Shanghai in accordance with its arbitration rules at the time of application. The arbitral decision is final and binding on all parties.

This privacy policy was last revised on November 24, 2025，and will take effect on March 10, 2025