1. Introduction

Welcome to DrNecky App ("we," "us," or "our"). We are committed to protecting the privacy and personal data of our users in accordance with the General Data Protection Regulation (GDPR) of the European Union and the California Consumer Privacy Act (CCPA) / Consumer Privacy Rights Act (CPRA) of the United States, as well as other applicable privacy laws in North America and Europe.

This policy explains how we collect, use, disclose, and protect your personal information when you use our mobile application and services.

2. Personal Information We Collect

To help you better understand how we collect and use your personal information when providing services, we have compiled this Personal Information Collection List.

Only when you use our specific services in corresponding scenarios will we collect your relevant personal information according to the "minimum necessary principle" for the purpose of providing services to you.

2.1 App Launch

Usage Scenario	Personal Information Scope	Collection Purpose
App Launch	Operation Records	When you use Dr Necky services, we collect your product log information, such as login history, interaction records, and usage history, so that you can view your historical records on the client. This is also used for customer service feedback processing. To improve your product experience, we may synchronize the aforementioned information to subsequent versions of the product.
App Launch	Device Information	To ensure you can normally use our product services, maintain the normal operation of basic product functions, improve product experience, and ensure account security, we will receive and record the device information of your mobile phone, smart watch, and smart earbuds, including device name, device type and version, device identifier, system version, IP address, MAC address, application ID, network type, and sensor information.
App Launch	Installation Environment	To ensure account security and create a healthy and safe product environment, we collect your installation and usage environment information, such as installed application list, process and crash records, overall usage situation, and channel source information. This is used to combat behaviors that interfere with or disrupt the normal operation of services.

2.2 Account Login

Usage Scenario	Personal Information Scope	Collection Purpose
Account Login	Personal Information	We will obtain your personal information based on your selected registration and login method, which may include your Email number, Apple account, authorization information. This information will be used to bind your membership subscription and synchronize your usage records. If you do not provide such information, you will not be able to use these services normally.

2.3 Identity Verification

Usage Scenario	Personal Information Scope	Collection Purpose
Identity Verification (when necessary)	Name, ID Number, Contact Information	If you contact our customer service, we may require you to provide necessary personal information for identity verification to ensure your account security. To provide services based on your requests, with your authorization, our customer service personnel need to query or verify your relevant information within the scope of your authorization. We will take technical and managerial measures to protect your information security and use it within the necessary scope.

2.4 Paid Subscription

Usage Scenario	Personal Information Scope	Collection Purpose
Paid Subscription	Membership Subscription	If you subscribe to membership, we will collect your subscription records for your query and to protect your membership rights as much as possible.

2.5 Specific Access Permissions

Usage Scenario	Personal Information Scope	Collection Purpose
Specific Access Permissions	Storage Permission, Network Permission, Camera Permission, System Notification	You understand and agree that in the process of providing services, based on the functions and scenarios of the services, we may require you to enable specific access permissions to achieve the collection and use of information related to these permissions. For example: Storage Permission - When you upload images/files from your device to the product, save product content/videos to your device, or obtain product resources. Network Permission - When you use the network-connected functions in the product. Camera Permission - We need your camera permission to determine if users are properly wearing accessories and if face distance is appropriate. System Notification Permission - To push system messages or usage reminders. If you refuse to provide this, it will only prevent you from using that specific feature, but will not affect your normal use of other features.

3. Lawful Bases for Processing (GDPR Compliance)

We process your personal data only when we have a valid legal basis under GDPR. This includes:

• Consent: Where you have given clear consent to process your data for specific purposes (e.g., certain marketing activities).
• Contractual Necessity: Processing is necessary to perform our Terms of Service with you.
• Legal Obligation: Processing is required by law (e.g., tax laws).
• Vital Interests: To protect someone's life.
• Public Task: In the public interest.
• Legitimate Interests: Where we have a legitimate interest in processing your data, provided it does not override your rights (e.g., security, fraud prevention, business operations).

4. Your Rights (GDPR & CCPA)

Depending on your location, you have specific rights regarding your personal data:

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can ask us to correct inaccurate or incomplete data.
• Right to Erasure ("Right to be Forgotten"): You can request the deletion of your personal data under certain circumstances (e.g., data is no longer necessary, you withdraw consent).
• Right to Restriction: You can request that we restrict the processing of your data (e.g., while we verify its accuracy).
• Right to Data Portability: You can request to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You can object to the processing of your data based on legitimate interests or direct marketing.
• Right to Opt-Out (CCPA/CPRA): You have the right to opt-out of the "sale" or "sharing" of your personal information (as defined by CCPA/CPRA) for cross-context behavioral advertising.

5. International Data Transfers

Your personal data may be processed in the jurisdiction where our company is located or in other jurisdictions where our service providers are located.

For European Users: If you are located in the European Economic Area (EEA), your data may be transferred outside the EEA to countries that may not have equivalent data protection laws. We will ensure such transfers are lawful by implementing appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission, to ensure your data receives an adequate level of protection.

6. Children's Privacy (COPPA & GDPR)

We do not knowingly collect personal information from children.

Under GDPR: We do not knowingly collect data from children under the age of 16 (or the applicable age in your jurisdiction, which may be 13 or 14) without verifiable parental consent.

Under COPPA (US): We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without parental consent, we will delete that information.

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience. However, under European regulations, we will obtain your prior consent before placing non-essential cookies on your device. You have the right to withdraw your consent at any time.

8. Contact Us

If you wish to exercise your rights or have any questions about our privacy practices, please contact us at: [DrNecky@foodiezen.cn]

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