PRIVACY AGREEMENT

Updated: August 22, 2026  |  Effective Date: August 22, 2026

Zephyr application is a smart device management application provided by us. This policy explains how we collect, use and store your personal information when you use Zephyr to manage compatible smart devices and use AI-related services, and what rights you have. The key points are as follows:

Key Points

We will explain the types of personal information we collect from you and their corresponding uses so that you can understand the specific categories of personal information we collect for a specific function, the reasons for use and the methods of collection. When you use some functions, we will collect some of your sensitive information (including voice recordings and microphone audio) after obtaining your consent, unless it is necessary to collect it in accordance with relevant laws and regulations. Refusing to provide this information will only make you unable to use the relevant specific functions, but it will not affect your normal use of other features of the Zephyr app.

Currently, the Zephyr application will not actively share or transfer your personal information to third parties other than our affiliated companies and the service providers disclosed in this policy that are necessary to provide login and AI functions. If there is other sharing or transfer of your personal information, we will obtain, or confirm that the third party obtains, your express consent. In addition, we will conduct a risk assessment on providing information to external parties.

You can access, correct and delete your personal information through the channels listed in this policy, and you can also withdraw your consent, cancel your account, complain and report, and set privacy functions.

Index

If you want to know more detailed information, please read the corresponding chapters according to the following index:

  1. Information we collect
  2. Storage of information
  3. Information security
  4. How we use information
  5. Provided externally
  6. Your rights
  7. Change
  8. Protection of minors
  9. Contact us

1. Information We Collect

When you use the Zephyr application, we collect information that you actively provide, that is generated through use of the service, or that is required to connect and manage compatible devices, in order to provide services, keep the service running and protect account security.

1.1 Data Collection List

Data type Collection scenario Necessary?
Google account identifier (OpenID / email) Google sign-in and account synchronization Necessary
Bluetooth device identifier (MAC / device name such as Zephyr-xxxx) Search, connect and manage compatible devices Necessary
Nearby devices / location permission (required by Android) Bluetooth scanning to discover devices Necessary (system required)
Microphone audio Face-to-face translation when you hold to speak on the phone Function-necessary (not collected when unused)
Voice recording files Device-side recordings synced to the cloud for playback, download and transcription Function-necessary
Translation / simultaneous interpretation / transcription text AI service interaction records, used to display conversations Function-necessary
Network logs / device model / OS version / app version Service stability and troubleshooting Necessary
Storage read and write Download voice notes and cache themes Function-necessary

If you do not provide necessary information, you may be unable to sign in, connect a device, or use the related function. Other functions that do not depend on that information remain available.

1.2 Information We Do Not Collect

We do not collect your contacts, SMS, call logs, or precise geographic location for tracking. We do not access your photo album unless you actively use a photo-related theme feature. Nearby-devices or location permission on Android is requested only because the system requires it for Bluetooth scanning. We do not use it to continuously track your location.

1.3 Google Account Information

When you sign in with Google, we collect the Google account identifier and email address needed to create and authenticate your Zephyr account. We do not collect a separate mobile phone number for registration. If you refuse Google sign-in, you may be unable to use account-related services.

1.4 Bluetooth and Device Identifiers

To search, pair and manage compatible Zephyr earbud cases and other wearable devices, we collect Bluetooth configuration information and device identifiers, including the Bluetooth MAC address and device name (such as Zephyr-xxxx). The device name is used for device recognition. It is not personal identity information by itself, but it may be associated with your account so that you can manage multiple devices. If you do not provide this information, you will not be able to connect the software to the product, but this will not affect other functions that do not require a device connection.

1.5 Voice Data Processing Rules

Voice recordings are generated on the compatible device. After they are synced to the cloud, they are stored in encrypted form for 24 hours and then deleted automatically. Transcription is completed by cloud AI. Transcription text is deleted together with the related recording. You may also delete notes manually in the App. Microphone audio is collected only when you actively use face-to-face translation and hold to speak on the phone. We do not continuously record in the background.

1.6 After-Sales Service and Customer Support

When providing after-sales service and customer support, we may ask you to provide information such as your name, email address or order-related details to verify your identity. If you refuse to provide such information, your issue may not be handled properly, but this will not affect your normal use of other functions.

1.7 Third-Party SDKs

In order to provide sign-in, device connection, AI translation and stable operation of the application, we may access software development kits (SDKs) provided by third parties, including Google. How those third parties collect and use personal information is governed by their own service agreements and privacy policies. Please also read Section 5 of this policy.

Exceptions to Consent

In accordance with relevant laws, regulations and national standards, we may collect and use your relevant personal information without seeking your authorization and consent in the following situations:

  1. Relevant to the personal information controller’s performance of obligations stipulated in laws and regulations;
  2. Directly related to national security and national defense security;
  3. Directly related to public safety, public health, and major public interests;
  4. Directly related to criminal investigation, prosecution, trial and execution of judgment;
  5. To protect your or other individuals’ life, property and other major legitimate rights and interests, but it is difficult to obtain your authorization and consent;
  6. The personal information collected is disclosed to the public by you yourself;
  7. Your personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
  8. Necessary to sign and perform a contract at your request;
  9. Necessary to maintain the safe and stable operation of the products or services provided, such as discovering and handling product or service failures;
  10. Necessary for legitimate news reporting;
  11. When it is necessary to carry out statistical or academic research in the public interest, and when providing the results of academic research or description to the outside world, the personal information contained in the results will be de-identified;
  12. Other situations stipulated by laws and regulations.

Please understand that the functions and services we provide are constantly updated and developed. If a function or service is not described above and your information is collected, we will separately explain the content, scope and purpose of information collection through page prompts, interactive processes or announcements, to obtain your consent.

2. Storage of Information

2.1 Where Information Is Stored

We store collected personal information on the user’s mobile device as needed to provide local functions. Account data, encrypted voice notes and AI processing records may also be stored on cloud servers operated by us or our service providers. Such cloud servers are located in regions operated by Google Cloud. Voice notes stored in the cloud are encrypted.

2.2 Duration of Information Storage

Generally speaking, we only retain your personal information for as long as necessary to fulfill the purposes of the service, for example:

When our products or services cease operations, we will notify you in the form of push notifications, announcements, etc., and delete or anonymize your personal information within a reasonable period.

3. Information Security

We strive to protect user information security to prevent loss, improper use, unauthorized access or disclosure of information.

We will use security protection measures within a reasonable security level. For example, we will use encryption technology (such as SSL/TLS), access control and anonymization to protect your personal information. Voice notes stored in the cloud are encrypted.

We use continuously improving technical means to strengthen the security of the software installed on your device. For example, we encrypt some information locally on your device for safe transmission.

We have established management systems, processes and organizations to ensure information security. For example, we strictly limit who can access information, require them to comply with confidentiality obligations, and conduct audits.

If a security incident such as personal information leakage occurs, we will activate an emergency plan to prevent the incident from expanding, and inform you in the form of push notifications, announcements, etc.

4. How We Use Information

4.1 Stated Usage Scenarios

Your personal information will be used in the usage scenarios clearly stated in the “Information We Collect” clause, including:

  1. Creating and authenticating your account through Google sign-in;
  2. Searching, pairing, connecting and managing compatible Zephyr devices;
  3. Providing AI translation, simultaneous interpretation, voice-to-text and voice note functions;
  4. Downloading or caching themes and other device content;
  5. Maintaining service security, diagnosing failures and improving stability;
  6. Responding to your after-sales and support requests.

4.2 Related Usage Scenarios

Your personal information may also be used in the following scenarios that are directly or reasonably related to the purposes stated above:

  1. Sending you service notifications, such as novice guides, device connection status, firmware update reminders, and results of account or data deletion requests;
  2. Recording operational information such as crash data, overall usage and performance data, in order to ensure service security and understand how the application operates. We do not combine analytics data with personally identifiable information beyond what is needed for these purposes.

4.3 Use Beyond Original Purpose

If we use your personal information beyond the purpose stated at the time of collection and the scope that is directly or reasonably related, we will inform you again and obtain your express consent before using your personal information.

5. Provide to External Parties

To provide Zephyr services, we use the following categories of third-party services. We share only the information necessary for the corresponding function:

Apart from the above, we will not actively share or transfer your personal information to other third parties, except to our affiliated companies where necessary to provide the services. If other sharing or transfer is needed, we will obtain, or confirm that the third party obtains, your express consent.

We will not publicly disclose the personal information we collect. If public disclosure is necessary, we will inform you of the purpose, the type of information disclosed and any sensitive information that may be involved, and obtain your express consent.

As our business continues to develop, we may conduct mergers, acquisitions, asset transfers and other transactions. We will inform you of the relevant circumstances and continue to protect, or require the new controller to continue to protect, your personal information in accordance with laws and regulations and standards no lower than those required by this policy.

In addition, in accordance with relevant laws, regulations and national standards, we may share, transfer, and publicly disclose personal information in the following circumstances without obtaining the prior authorization and consent of the personal information subject:

  1. Relevant to the personal information controller’s performance of obligations stipulated in laws and regulations;
  2. Directly related to national security and national defense security;
  3. Directly related to public safety, public health, and major public interests;
  4. Directly related to criminal investigation, prosecution, trial and execution of judgment;
  5. 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 consent of the individual;
  6. Personal information disclosed by the personal information subject to the public on his or her own initiative;
  7. Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
  8. Other situations stipulated by laws and regulations.

6. Your Rights

During your use of the Zephyr application, you may access, correct and delete your personal information, withdraw consent, and cancel your account through in-app settings where available, or by contacting us. You may also delete voice notes in the App. In addition, we have set up a complaint reporting channel, and your opinions will be handled in a timely manner.

Account Deletion Request

If you wish to delete your Zephyr application account and all associated user-related data, please submit your deletion request following the procedure below:

Please send an email to: baos@baos.cn

Email subject: Zephyr Account Deletion Request

Please provide the Google login email address you used to sign in to Zephyr within the email for identity verification.

Scope of data deletion: After we verify your valid request, we will delete your account-related data including user ID, email address, bound device identifiers, voice notes, AI interaction records and your application configuration data.

Data retention note: Only logs required by applicable law will be retained for the minimum statutory retention period and will be erased automatically afterwards; retained data will not be used for other business purposes.

Processing time-limit: We will complete account and associated data deletion within 30 calendar days upon receipt of a valid verified request, and notify you via email once completed.

7. Change

We may revise this policy from time to time. When the terms of the policy change, we will display the changed policy to you in the form of push notifications and pop-up windows when you log in and when the version is updated. Please note that only after you click the consent button in the pop-up window will we collect, use and store your personal information in accordance with the updated policy. If you continue to use the Zephyr application after the updated policy takes effect and you have given consent, it will be deemed that you agree to the updated policy.

8. Protection of Minors

We attach great importance to the protection of minors’ personal information. The Zephyr application is not directed to children under the age of 13. If you are under the age of 13, please do not use Zephyr application services and exit this application immediately. If you are the guardian of a minor and you have questions about the personal information of the minor under your guardianship, please contact us through the contact information in this policy.

9. Contact Us

When you have complaints, suggestions, or issues related to personal information or minors’ personal information, you can contact us through the company’s customer service center. You can also send your questions to baos@baos.cn.

We will review the issue as soon as possible and respond within fifteen working days after verifying your user identity.