Last Revised: January 20, 2021

INTRODUCTION

Greysh Co., Ltd.. (“our”, “we”, “us” or the “Company”) is committed to respect the privacy and Personal Information of the users (“user” or “you”) in connection with the use of our mobile application and/or by accessing our website http://www.greysh.cn/ (collectively the “Service”).

• Our Service is primarily designed to empower consumers to make informed decisions and deter illegal and fraudulent calling activities.

• Our Service plays a key role in enhancing connectivity and thwarting intrusive and fraudulent calls, by introducing a variety of smart features that empower consumers to make informed decisions and reduce the risks of the user community from being targeted by malicious or misleading activities. These features include:

  • Reporting and blocking spam: our users can choose to report and block numbers to be added to their personal spam call list, and potentially a regional spam call list. In the event a particular number was reported as spam by a certain number of users, other users will be notified if they receive a call from that same number.

  • Live Caller ID and Spam detection: our Live Caller ID displays the name of the caller before the consumer answers the call, and flags if the number was reported as spam.

  • Number search (reverse lookup): individuals, including those who are not registered users with , may manually search a number on 's web-based platform in order to ascertain the identity of the caller and whether a number was reported as spam. The contact information collected by is used solely to empower individuals to identify incoming calls from unknown sources, identify unknown numbers through the use of reverse numeric lookup, as well as to report and block fraudulent, intrusive or inappropriate calls.

• We designed our features to better respond to deceptive and abusive practices aided by anonymity, both in telemarketing as well as in other abusive or deceptive practices (such as abusive calls).

• Our goal is to promote consumer privacy by allowing them to know who is calling them, as well as to promote accountability throughout the industry.

• Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or means of enforcement.

THIS PRIVACY POLICY

This privacy policy (“Privacy Policy”) outlines our practices with respect to the information we collect from you when you use the Service, and the manners in which we use such information.

In addition to this Privacy Policy, please also review our Terms of Use, in which this Privacy Policy is incorporated thereto by reference, along with such other policies of which you may be notified by us from time to time. The definitions in our Terms of Use apply to this Privacy Policy unless stated otherwise. We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices and your rights in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals

uses, collects, and stores Personal Information that we collect or receive from or about you such as in the following cases:

• When you browse or visit our website, http://www.greysh.cn/ (“Website”).

• When you make use of, or interact with, our Website.

  • When you create an account, and when you log in.

  • When you want to find out who called.

  • When you contact us and/or when you submit a request.

• When you make use of, or interact with, our mobile software application, and any other software, that we license (each individually, and collectively, the “App”).

  • When you download our software (or App(s)), create an account, when you log in and make use of the App.

  • When you download our software (or App(s)), create an account, when you log in and make use of the App. When you contact us.

In our Privacy Policy you will learn about:

• WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

• HOW WE SHARE YOUR PERSONAL INFORMATION

• INTERACTION WITH THIRD PARTY PRODUCTS

• ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

• FOR HOW LONG DO WE RETAIN THE INFORMATION WE COLLECT?

• USER RIGHTS

• CHILDREN’S INFORMATION

• HOW DO WE SAFEGUARD YOUR INFORMATION?

• LOG FILES

• ANALYTIC TOOLS

• UPDATES OR AMENDMENTS TO THE PRIVACY POLICY

• HOW TO CONTACT US

• 1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED?

  • When you browse, or visit, our Website.

    • Specific Personal Information we collect – When you visit our Website, we collect Personal Information submitted directly by you, or Personal Information transmitted automatically from your device using various standard technologies, such as cookies, analytic tools, digital identifiers, log files, web beacons or other similar technologies.

    • Why is the Personal Information collected and for what purposes? We collect the Personal Information for the purposes of tracking your activity and use of our Website, your type of browser, pages you visited, the time and date of your visits or the links you click on, to improve quality and design of the Service, including without limitation, saving you the trouble of re-entering data and queries, to personalize and customize the Service, and to track your use of the Service and generate statistics regarding the Service. In addition, we collect this Personal Information to enhance and personalize your experience, customize the advertising content we display, and to perform research, technical diagnostics, analytics, or statistical purposes.

    • Legal basis (GDPR only, if applicable) – Consent and Legitimate interest (e.g., essential cookies).

    • Third parties with whom we share your Personal Information – 3rd party platforms such as for the following purposes: For more information, please read our cookies policy.

    • Retention period – For more information, please read our cookies policy.

    • Consequences of not providing the Personal Information – Certain Website features may not be available. Read more about the purposes of each cookie.

  • When you make use of, or interact with, our Website

    a. When you create an account and when you log in.

    • Specific Personal Information we collect – We will collect your full name, phone number and email address, and/or the Google or Microsoft log-in details.

    • Why is the Personal Information collected and for what purposes? We collect the Personal Information for the purpose of: (i) allowing you to create your account, (ii) allowing you to log in to the services, and (iii) allowing you to enjoy features available to registered users only (including, without limitation, the use case Website features to find our who called you (more information see below the use case b). To complete the registration, we may contact you with the number your provided us (via inbound call or SMS) in order to authenticate your identity and prevent fraud.

    • Legal basis (GDPR only, if applicable) – Depending on the context, processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract, and legitimate interest (e.g. to sign-up)

    • Third parties with whom we share your Personal Information – 3rd party platforms such as for the following purposes: CRM platform, spam blocking platform and cloud.

    • Retention period – Your Personal Information will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws

    • Consequences of not providing the Personal Information – Where we do not process the Personal Information, we will not be able to: (i) allow you to create your account, (ii) allow you to log in to the App, and (iii) allow you to enjoy features available to registered users only.

    • Marketing communications - We will collect your full name and email address to send you marketing communications in accordance with your consent. We share the Personal Information with 3rd party platforms such as for the following purposes: CRM platform and cloud. Your Personal Information will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. If you do not provide us with the data, we cannot send marketing communications.

Finally, please note that some of the abovementioned Personal Information will be used for detecting, taking steps to prevent, and the prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Information and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes, we may be shared with third parties (including ad networks, advertising companies and service providers) in any of the above circumstances, as well as for the purpose of developing or delivering tailored or targeted advertising (whether via our Service or Websites), for the purpose of improving our Service, conducting business analysis or other business purposes. This information may be combined with information we collect from other sources, to the extent that the information remains anonymous. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

• 2. HOW WE SHARE YOUR PERSONAL INFORMATION

In addition to the recipients described above, we may share your Personal Information as follows:

• With our business partners with whom we jointly offer products or services. We may also share Personal Information with our affiliated companies.

• To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, including, without limitation, in order to enforce intellectual property rights or to exercise other legal rights; to establish or exercise our rights to defend against legal claims; if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud or other wrongdoing, safety of person or property, violation of our policies, to enforce our policies or as otherwise required in order to comply with the applicable laws and regulations.

• We may share Information, including Personal Information, with our parent company, any subsidiaries, joint ventures, strategic alliances, or other companies under a common control (collectively "affiliated companies").

• If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Information to such third party (whether actual or potential) in connection with the foregoing events;

• In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Information in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or

• Where you have provided your consent to us sharing or transferring your Personal Information (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy. If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to support@greysh.com.cn.

• 3. INTERACTION WITH THIRD PARTY PRODUCTS

Our Privacy Policy only addresses the use and disclosure of information we collect from you. We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). To the extent that you disclose your information to other parties via our Service (whether our Website or application; e.g. by clicking on a link to any other website or location or by providing information via API) or via other sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. We are not responsible for the privacy practices or the content of such Third Party Services. Accordingly, we encourage you to review the terms and conditions and privacy policies of those sites before providing your Personal Information to them.

• 4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

External transfers: Where we transfer your Personal Information outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your Personal Information.

• 5. FOR HOW LONG DO WE RETAIN THE INFORMATION WE COLLECT?

5.1. Retention of your Personal Information. In addition to the retention periods mentioned above, in some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Information perpetually. Regarding retention of cookies, you can read more in our cookie policy.

5.2. If your Personal Information was directly volunteered to us, either by yourself or by another User, we will retain such Personal Information unless we were instructed by you to delete it. You may approach us at any time with a request to delete your Personal Information, by sending us an email at: support@greysh.com.cn.

• 6. USER RIGHTS

Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

You can exercise your rights by contacting us at support@greysh.com.cn. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

Notwithstanding anything to the contrary, you acknowledge that the same information, including without limitation, the Personal Data provided to by you may have already been provided, or will be provided, by other users, or may have already been collected, or will be collected by independently, or from other sources, or may be available on public sources or publicly available data sources. For the avoidance of doubt, processing of information in such cases (e.g., when it was provided the same Personal Data also by other sources,), including without limitation, the Personal Data shall not be considered a breach of our Terms of Use and/or your rights (even when you request to delete the contact details that you had uploaded to the App).

Deleting your account: Should you ever decide to delete your account, you may do so by emailing support@greysh.com.cn. If you terminate your account, any association between your account and Personal Information we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

• 7. CHILDREN'S INFORMATION

Our Service is not intended for minors below the age of 16 years or otherwise below the legal age for providing consent that is not subject to authorization by the holder of parental responsibility, in accordance with the laws in the jurisdiction your reside (“Age of Consent”), and we will not knowingly collect personal information from children. If we become aware that a user is under the age of Age of Consent, we reserve the right to remove the Personal Information from our files and systems. We reserve the right to request proof of age at any stage so that we can verify that children are not using the Service. If you believe that we might have any such information, please contact us at support@greysh.com.cn.

• 8. HOW DO WE SAFEGUARD YOUR INFORMATION?

We take great care in implementing and maintaining the security of the Service and your information and we have implemented appropriate technical, organizational and security measures designed to protect your Personal Information. We employ industry standard procedures and policies to ensure the safety of our users’ information, and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

If you feel that your privacy was treated not in accordance with our Privacy Policy, or if any person attempted to abuse our service or acted in an inappropriate manner, please contact us directly at support@greysh.com.cn.

• 9. LOG FILES

We use log files. We use such information to analyze trends, administer the Website/App, track users’ movement around the Website/App, and gather demographic information.

• 10. ANALYTIC TOOLS

Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

Firebase Analytics. We also use “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply.

AppsFlyer. We use a tool called “AppsFlyer”, a mobile attribution and marketing analytics platform to understand the use of our services. AppsFlyer is exposed to the following data: (i) unique identifiers and technical data, such as IP address, User agent, IDFA (Identifier For Advertisers) or Android ID (in Android devices); and (ii) technical data regarding your operating system, device attributes and settings, applications, advertising opt-out signals, Google Advertiser ID, in-app events, device motion parameters and carrier. The use of this data allows us to analyze our campaigns and performance, as well as your habits and characteristics. For example, the data AppsFlyer receives includes downloads, impressions, clicks and installations of their mobile applications, mobile device use and data regarding in-app events. AppsFlyer’s terms of use (available at https://www.appsflyer.com/terms-of-use/) and privacy policy (available at https://www.appsflyer.com/privacy-policy/) also apply to the use of AppsFlyer.

Advertising Partners. Through our services, we allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners will use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may let us know.

We reserve the right to remove or add new analytic tools.

• 11. UPDATES OR AMENDMENTS TO THE PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. If we implement significant changes to the use of your Personal Information in a manner different from that stated at the time of collection, we will provide notice of such changes of this Privacy Policy on the Service and/or we will send you an e-mail regarding such changes to the e-mail address that you volunteered, or by other means. To the maximum extent permitted by law, such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Service after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

• 12. HOW TO CONTACT US

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us a contact us request to support@greysh.com.cn.