Effective Date: July 12, 2019

This Privacy Policy describes what information LingGui Technology (Beijing) Co., Ltd. (developer of Zengine SDK, "we", "our" or "us") will collect and how we use such information. We receive information about you from various sources (the "Services"), including: 1) you use the functions or services provided by Zengine SDK. 2) you use Applications developed by us or third-party developers with Zengine SDK 3) you visit and use our website nlptech.com. 

By using our Services, you agree that we may treat your information in the ways as described in this Privacy Policy. If you do not agree with any term of this Privacy Policy, you may not use our Services. 

1. What Information We Collect From You
	a. Information You Provide to Us
		i. Account Information
			We have some functions which require users to login with their accounts. In these cases, we may collect information relating to your account, such as your account id, name, profile, email, address, password, phone number and any other information the function required and you choose to provide. 
		ii. Input Information
			When you are using a keyboard built with Zengine SDK, we may collect input information with your consent. The information may include the text you type in a textbox, the environment you type in and how you type it. Please notice that the information is anonymous and no sensitive data is collected. The input information is masked with random generated id. Any password is ignored. Numbers and email addresses are transformed into special symbols and can not be recovered again.  
		iii. Other Information You Choose to Provide
			Including the information you provide as advice, feedback or report, and what you provide to us during our survey.  
	b. Information We Collect Automatically
		i. Device Information
			When you are using our Services, the information of your device is automatically collected, including the hardware model, operating system and its version, language preference, unique device identifiers, mobile network information and information about your use of the Services. Please notice that we may use your Android Identifier to calculate how many models are activated, based on which we will charge or be charged from business partners. 
		ii. Usage Statistics
			When you are using our Services, how you use them will be automatically recorded, including the software environment information, your actions and procedures, which will help us improve the Services. The information is anonymous. 
		ii. Crash Log
			When you encounter a software error ("Crash") or Application Not Responding ("ANR"), we will collect the software environment information, software logs and Stack Trace information to help us find out and fix the problem. The information is anonymous. 
		iv. Information Collected Using Cookies
			When you visit our website via browsers or WebViews on mobile devices and interact with our Services, we and our service providers use various tracking technologies, including cookies and web beacons, to collect information about you. 
	c. Information We Collect From Other Sources
		We also collect information from user ratings and reviews from third-parties like App Store and Google Play. Information related to us on social networks and forums will also be collected.  

2. Use of Information
	We may use the information we collected in following purposes:
	a. Calculate how many models are activated, based on which we will charge or be charged from business partners;
	b. Provide, maintain and improve the Services. For example make new dictionaries and train new language models;
	c. Manage your account and send you related information, including confirmations, updates, technical notices, security alerts and support and administrative messages;
	d. Monitor and analyze trends, usage and activities in connection with the Services;
	e. Locate and fix software bugs; 

3. Sharing of Information
	We may share information about you as follows:
		a. With vendors, consultants and other service providers who need access to such information to carry out work or perform services on our behalf. For example third-party analytics platforms like Firebase; 
		b. In response to a request for information if we believe the disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process; 
		c. With your consent; 

4. International Transfer and Storage of Your Personal Data
	In certain circumstances we may need to transfer your Personal Data to countries outside the country in which the data was collected. International transfers of your Personal Data will be protected by appropriate safeguards. 
	All data is stored with secure methods and with limited/restricted access to persons authorized by us. We may store Personal Data on remote servers ("Servers") operated by a cloud service provider. 
	a. The personal data collected from the United States ("U.S.") will be transferred to and stored on Servers in the U.S.  
	b. The personal data collected from the People's Republic of China ("P.R.C") will be transferred to and stored on Servers in the P.R.C. 
	c. The personal data collected from the European Union ("EU"), United Kingdom, Lichtenstein, Norway, or Iceland will be transferred to and stored on Servers in the EU. 
	d. The personal data collected from India will be transferred to and stored on Servers in India. 
	e. The personal data collected elsewhere will be transferred to and stored on Servers in the U.S., the EU, India or Singapore.  

5. Personal Data of Children
	We do not knowingly collect personal information from any children under the age of 16 without such consent. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. Please contact us if you believe we have any personal information from any children under the age of 16 without parental/guardian consent. We will take reasonable steps to delete it as soon as possible.

6. Changes to This Privacy Policy
	We reserve the right to amend this Privacy Policy at any time. We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected. You will know if the Privacy Policy has changed since the last time you reviewed it by checking the "Effective Date" included at the beginning of the document. 

7. Contact Information
	If you have any questions or concerns regarding privacy using the Services, you may contact us at: privacy@nlptech.com.

EU Residents

If you are a resident of the European Union ("EU"), the United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the "GDPR") with respect to your Personal Data, as outlined below.

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email privacy@nlptech.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it violates the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

1. Access
You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.

2. Erasure
You can request that we delete some or all of your Personal Data from our systems.

3. Withdrawal of Consent
If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

4. Objection
You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.