Bolo AI Keyboard Privacy Policy

Last Updated: June 10, 2026

Effective Date: June 10, 2026

Version: 20260610V1

SHANGHAI XIAOCHUAN TECHNOLOGY LIMITED (hereinafter referred to as "【Bolo AI Keyboard】", "we" or "us") is the provider and operator of 【Bolo AI Keyboard】 application software and services (hereinafter referred to as the "Software"). We fully respect your privacy and will do our utmost to protect the security of your personal information. In the process of providing you with products or services (collectively referred to as the "Services"), we may collect and use your personal information based on your consent or in accordance with applicable laws and regulations. This Privacy Policy (hereinafter referred to as the "Policy") is designed to help you understand how we collect, use, disclose, process and protect your personal information provided by you when using 【Bolo AI Keyboard】 products or services, what rights you have in relation to such personal information, and how we safeguard such rights. This Policy applies to all products and services provided by 【Bolo AI Keyboard】, including applications, mini-programs, web pages for computers and mobile intelligent terminals, software development kits (SDK) and application programming interfaces (API) used by third-party websites and applications, or other forms that may appear in the future.

It should be specifically noted that this Policy does not apply to services provided to you by other third parties. You may receive content or web links provided by third parties, please carefully consider whether to access the links, content, products and services provided by third parties. Before submitting personal information to a third party, please carefully read the privacy policy of such third party.

To ensure that you fully understand this Privacy Policy and make independent choices, we try to explain to you in clear and easy-to-understand language, and clearly mark or highlight key reading content (especially in the form of bold, capitalization, underlining, etc.). We will also display a pop-up window when you use our Services for the first time, and guide you to focus on the core content of this Privacy Policy.

Please read this Policy carefully before using our products or services, submitting personal information to us or consenting to our collection of your personal information, and understand our practices regarding your personal information. Please visit frequently to learn about updates to this Policy. If this Privacy Policy is updated, we will issue a notice on the relevant product or website to keep you informed of the updates. Your access to or use of our Services after we issue such notice constitutes your acceptance of the updated Privacy Policy. You can check the "Last Updated" date at the top of this Privacy Policy to confirm the latest update time of the Privacy Policy.

If you have any questions, please feel free to contact us at: 【privacy@dlightek.com

You can also access this Privacy Policy through: 【Bolo AI Keyboard】 APP > Settings > Privacy Policy

This Privacy Policy will help you understand the following

1. How we collect and use your personal information

2. How we store and protect your personal information

3. How we share, transfer and disclose your personal information

4. How your personal information is transferred across borders

5. Your rights regarding your own personal information

6. How we handle personal information of children

7. Third-party service providers and their services

8. Supplements and updates to this Policy

9. How to contact us

1. How We Collect and Use Your Personal Information

1.1 General Overview

【Bolo AI Keyboard】 firmly believes that basic privacy rights should not vary depending on where you live. Therefore, we regard any information relating to a natural person who is identified or identifiable, especially the natural person's name, identity information, location data, online identifiers, or data specific to the natural person's physical, physiological, genetic, psychological, or related data as "personal information", regardless of where the natural person resides.

We will only collect information necessary for specific, concrete, clear and legitimate purposes, and shall ensure that your information will not be further processed in a manner inconsistent with these purposes. If we intend to use your personal information for other purposes not explicitly stated in this Privacy Policy, we will obtain your consent again.

When collecting your personal information, we will collect it through the following three ways: 1) information you directly provide to us; 2) information we collect automatically through automated means during your use of the Software (such as device information, service log information); 3) information we obtain from other sources.

You have the right to choose whether to provide personal information when using 【Bolo AI Keyboard】 products or services or when we request it. You are not required to provide personal information to 【Bolo AI Keyboard】. However, in some cases, if you choose not to provide it, 【Bolo AI Keyboard】 will not be able to provide you with relevant products or services, nor respond to or solve the problems you encounter. We will only collect and use your personal information for the purposes described in this Policy. Examples of your personal information we collect are set forth below.

1.2 Main Business Functions and Collection and Use Scenarios of 【Bolo AI Keyboard】The main business function of the Software is to provide you with online text input, voice input, quick search and other functions.

1.2.1 Ensuring Operational Safety and Product Optimization

(1) Device-related information: To ensure necessary compatibility between the Software and devices and secure services, when you start to use the Software services, we will receive and record relevant information of the mobile device you use according to your specific operations in the Software and the specific permissions granted during the installation and use of the Software (including ROM version number (mobile device brand, mobile device model), device SN number, operating system version information, system language, time zone information, build software version, system account ID, hardware device identifier GAID (Google Advertising ID), network type (PLMN (Mobile Country Code MCC, Operator MNC), IP address), application version number, application package name information, installation channel information, relevant information of the location of the mobile device (including the country or region location information of the mobile device authorized by you, network access method).

(2) Service log information: When you use the Software services, to improve and optimize product experience and service quality through data statistical analysis, ensure service stability and network security. We will automatically collect detailed usage of our services and save them as service logs, including published information, access time, access opening times, usage duration, event information (errors, crashes, restarts, upgrades), and other log information generated by the device.

Please note that such separate device information and service log information cannot identify the identity information of a specific natural person. If we combine such non-personal information with other information to identify the identity of a specific natural person, or use such non-personal information in combination with personal information, such non-personal information will be regarded as personal information during the combined use. If we do so, we will anonymize and de-identify such personal information, unless we obtain your authorization or as otherwise required by laws and regulations. The above information is basic information necessary to provide services. If you refuse to provide such information, we may not be able to provide you with relevant services of the Software.

Please note that we will also collect the above device information and service log information in various business functions and scenarios of the Software (there will be slight differences in different business functions and scenarios).

In this business function and scenario, we need to obtain your permission to read mobile network information and device parameter information.

1.2.2 Providing Text and String Input Functions

1.2.2.1 Text and string input is the basic function service of Bolo AI Keyboard, and you can use it without providing personal information. Please note that although the text content you input may contain personal information of you or others, we will not identify the specific text content, and only conduct technical analysis by extracting strings (without identifying personal information) to realize the input function.

1.2.2.2 When you use the quick quote function, we will record the quote content you select to recommend and help you find more interesting quote content. If you do not wish to use the personalized recommendation content provided by us or receive recommendation services based on such data, you can turn off personalized recommendations through the following steps: APP > Settings > Quick Quotes. Please note that permission management methods may vary in different versions.

1.2.3 Providing Voice Input FunctionWhen you use the voice input function service, we will obtain the voice information you actively upload, process the voice information in real time according to your needs and feedback the transcribed text to you to provide you with the voice-to-text function. Such information is necessary for the function service. If you do not provide it, you will not be able to use this function service.

When you use the voice input function service, we need to call the microphone permission of your device to obtain your voice information, which is a necessary system permission for the function service. If you refuse to enable it, you will not be able to use this function service.

1.2.4 Providing AI Emoji FunctionWhen you use the AI emoji function service, we will collect the image information you upload to provide you with the functions of making emojis and intelligently recognizing image subjects. We will delete the original images you upload after the service is completed. Such information is necessary for the function service. If you refuse to provide it, you will not be able to use this function service.

1.3 Other Circumstances Where We May Collect Your InformationUnder circumstances permitted by law, we may obtain your personal information from other individuals, commercial entities, public channels or other third parties instructed by you, other partners who assist in providing our products or services and help ensure information security and fraud prevention, and other legitimate sources. We will explain to you at the time of collection and obtain your consent.

We may also collect other information about you, your device or the use of the service through other means, which will be explained to you at the time of collection and obtain your consent.

To better improve our product layout and provide you with better services, we may conduct research, statistical analysis and prediction on the collected information in an anonymized manner (including using anonymous data for machine learning or model algorithm training), so as to continuously improve the speed and quality of algorithm model recognition and response, and enhance the intelligence of services. However, we will not identify your specific identity based on your input content. We will process the collected personal information by adopting technical measures and other necessary measures, so that such data cannot be re-identified to a specific individual and cannot be restored. In accordance with applicable laws and regulations, the use of such processed data does not require further notice to you or your consent. If you do not agree that we use anonymous data for machine learning or model algorithm training, you can turn it off at any time through the "APP - Settings - About" page. After turning it off, the content you input in subsequent use of our products and services will not be used for service optimization.

2. How We Use Cookies and Similar Technologies

2.1 What Are Cookies and Similar TechnologiesWith the iterative update of our product functions, to ensure the normal operation of the Software and provide you with a more accessible experience, recommend content or advertisements you are interested in, we may store small data files named Cookies on your mobile device in our existing or future products and services. Cookies usually contain identifiers, site names and some numbers and characters. Our websites, online services, interactive applications, e-mail and other information services may use cookies and other similar technologies, such as pixel tags and web beacons. Because the information collected through Cookies and similar technologies does not contain any of your personally identifiable information, we usually regard it as non-personal information. However, if the laws of relevant countries regard Internet Protocol (IP) addresses or similar identification marks as personal information, we will also comply with the provisions of the laws of such countries.

2.2 Why We Use Cookies and Similar TechnologiesWe and our partners use Cookies or similar tracking technologies to better understand the usage of mobile software on your device, understand the frequency of your use of applications, events occurring in the application, cumulative usage, performance data and where you download the application; we and partners use Cookies or similar tracking technologies to analyze trends, manage websites, track user behavior on websites, and collect overall audience characteristic information of our user base.

We will not use Cookies for any purposes other than those described in this Privacy Policy. You can manage or delete Cookies according to your own preferences. You can clear all Cookies saved on your mobile device through the path provided in the "Settings" option in the Software. You can also choose not to be tracked and opt out of interest-based advertising by deleting Cookies and restoring (clearing) mobile terminal settings (content and data).

3. How We Store and Protect Your Personal Information

3.1 How We Store Your Personal InformationPersonal information collected based on your consent will be stored in accordance with the laws and regulations on personal privacy data protection of relevant countries. Where local laws and regulations do not prohibit, we may also store the collected personal information in countries or regions outside the country where the business is located.

At present, 【Bolo AI Keyboard】 may store your personal information in: Frankfurt. Specifically,The personal information collected and generated in our business will be stored on servers in Frankfurt.

In the future, we may introduce servers in other regions or countries, and we will update this Policy accordingly.

Whether personal information is stored in the country where the business is located or in other countries or regions without violating legal provisions, we will store it in accordance with the provisions of relevant laws and regulations on data storage. We will also take into account the characteristics, scope, purpose of personal information processing, risks encountered in processing, and possible serious consequences of damage, and implement necessary security measures. For example, we will store collected personal information by means of encryption and de-identification. Meanwhile, we will store personal information only for the shortest storage period necessary for business development, unless you agree to extend the retention period or it is permitted by law. Data exceeding the storage period, or data you request us to delete, will be deleted or other appropriate measures will be taken without violating the provisions of relevant laws and regulations.

3.2 How We Protect Your Personal InformationWe will also take other necessary means to ensure the security of your personal information, so as to prevent data from being abused, unauthorized access, and unauthorized modification, disclosure or destruction.

We implement security protection measures designed to protect your personal information, and regularly monitor our systems for possible vulnerabilities and attacks. We will use administrative, technical and physical protection measures to protect your personal information by considering the nature, processing method and security of personal information. We are constantly striving to improve these protection measures to ensure the security of your personal data.

Of course, it should be reminded that even perfect security measures cannot absolutely guarantee the occurrence of data storage security incidents. In the event of a security breach, we will report to the corresponding regulatory authorities in accordance with the requirements of relevant laws and regulations, and provide the type of personal data involved in the data breach, the number of data subjects, possible consequences of the data breach, and remedial measures we intend to take according to the requirements of regulatory authorities. We will take all possible measures to remedy or mitigate the damage and consequences caused by the data breach. Where permitted or required by laws and regulations, we will timely inform you of the possible or significant damage to you caused by the data breach, so that you can take appropriate measures in a timely manner to protect your rights as much as possible.

Since no website, Internet transmission, computer system or wireless connection is absolutely secure, in addition to the necessary security protection measures we take, users also need to strengthen privacy security risk awareness. For example, we are not responsible for any legal liability for the security of any data and information collected by third-party websites, links, products or services that you jump to through our services. Please be careful and carefully read the terms and conditions of such third parties for the data security problems caused by such third parties. If you find that some content, advertisements or functions of our website, products or services may be provided by third parties and may endanger your personal privacy and security, please contact us in time, and we will give priority to handling in accordance with laws and regulations.

4. How We Share, Transfer and Disclose Your Personal Information

In terms of sharing, transferring and disclosing your personal information, we uphold the principles and requirements of minimization, necessity and legal compulsion. Under normal circumstances, we will not share, transfer or disclose your personal information to the outside world. However, under the circumstances permitted or required by applicable laws and regulations, we may share, transfer and disclose your personal information in the following circumstances.

4.1 How We Share Your Personal InformationWe will not sell any personal information to third parties. To provide you with timely services, your personal information may be shared with affiliated companies of 【Bolo AI Keyboard】. We will only share your information within affiliated companies of 【Bolo AI Keyboard】 for legitimate and explicit purposes, and only share the information necessary to provide services, subject to the purposes stated in this Privacy Policy. If the relevant purposes are not included in this Policy, we will explain them in the privacy policy or notice of the corresponding specific products or services.

We may share necessary personal information with authorized third-party partners (including data storage service providers, etc.) to perform certain functions or provide you with better services and user experience. For example, our data storage service provider will provide us with cloud storage services to ensure the normal operation of such services. We conduct such sharing activities in accordance with the principles of minimization, necessity and legal permission. Before information sharing, we will sign strict confidentiality agreements with authorized partners, requiring them to process personal information in accordance with this Policy and applicable laws of your jurisdiction and adopt relevant confidentiality and security measures. In addition, we will also require them to provide data security functions and information security qualifications (such as classified protection assessment, information security management system, etc.). When we embed SDKs or other similar applications of authorized partners in the Software, we will fulfill the due diligence obligation and require the SDKs that obtain information to protect your data security. Specifically

To provide evaluation, analysis or other commercial services, we may also share your non-personal information with third parties. For example, we may use the summarized and sorted information to help partners (such as advertising service providers) understand the effectiveness, feedback and usage trends of their services.

In the event of merger, acquisition or bankruptcy liquidation, asset transfer and other related transactions, if personal information transfer is involved, we will require the company or organization that newly holds your personal information to continue to be bound by this Privacy Policy through agreements or other appropriate measures, and require such entities to adopt confidentiality and security measures not lower than those required by this Policy to process personal information.

4.2 How We Transfer Your Personal Information【Bolo AI Keyboard】 will not transfer your information to any other party except in the following cases

4.2.1 With your explicit consent.

4.2.2 If 【Bolo AI Keyboard】 is involved in a merger, acquisition or sale of all or part of its assets, which may affect your personal information, we will post a prominent notice via email and/or our website or other appropriate methods to inform you of any changes to the ownership, rights and choices of your personal information.

4.2.3 As described in this Privacy Policy or notified to you in other ways.

4.3 How We Disclose Your Personal Information【Bolo AI Keyboard】 may need to disclose your personal information as required by law, legal procedures, litigation and/or government departments and authorities. We may also disclose information about you if such disclosure is necessary or appropriate for national security, law enforcement or other matters of public importance.

In addition, we may share your personal information with the following parties

4.3.1 When we ask them to provide professional advice, we may share your personal information with our lawyers, accountants, auditors or similar advisors.

4.3.2 Investors and other relevant third parties, in the event of actual or potential sales or other corporate transactions, and related to our group entities.

4.3.3 Other third parties, for example, disclosing specific information with your authorization.

5. Cross-border Transfer of Your Personal Information

For the purposes described in this Privacy Agreement, in compliance with applicable laws and regulations of your region and with your authorization and consent, we may transfer your personal information to the resources or servers mentioned in Article 3 of this Policy for storage or processing. We may also transfer your personal information to third-party service providers and business partners, so your data may also be transferred to other countries or regions. The privacy protection laws of these countries or regions may be different, and the jurisdictions where these servers are located may or may not protect personal information according to the same standards as your jurisdiction. However, we will still strive to comply with our Privacy Policy to protect your personal information, and we will carry out corresponding cross-border transfer and other processing of personal information in accordance with the legal requirements of the country or region where the personal information is located.

If we transfer personal information outside your jurisdiction, whether to our affiliated companies or third-party service providers, we will comply with applicable relevant laws. We will take appropriate security and protection measures to ensure that all such transfers comply with applicable local data protection laws and regulations.

6. Your Rights Regarding Your Own Personal Information

As a data subject, you have a series of rights regarding personal information, including confirmation, access, correction, deletion, withdrawal of consent, and complaint (hereinafter referred to as "Request"). We fully understand and respect your rights. In accordance with applicable laws, such rights will also be subject to specific exclusions and exceptions. We will also take active measures to ensure the effective protection of your rights. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we will not charge fees for your legitimate and reasonable requests. However, for repeated requests beyond reasonable limits, we will charge a certain reasonable fee based on actual management expenses within the scope permitted by applicable laws. We may reject requests that are unreasonably repeated, require excessive technical means (for example, require development of new systems or fundamental changes in existing practices), pose risks to the legitimate rights and interests of others, or are very impractical, or violate mandatory legal provisions.

6.1 Right to Confirm and AccessWe inform you how we collect and process personal information through this Privacy Policy or privacy policies or notices in specific product service scenarios. You have the right to confirm or refuse such collection and processing by checking and other means. However, if you refuse, some functions that can only be used after your explicit authorization and consent may not be available. For personal information you have provided to us, you can directly inquire in the interface of our products or services. For inquired cases, you can send an email to 【privacy@dlightek.com】. Upon receipt of your email, we will process it in a timely manner.

6.2 Right to Correction and DeletionWhen your personal information changes, or when you find that the personal information we have collected and processed about you is incorrect or incomplete, you have the right to request us to make corrections or supplements. For part of your personal information, you can directly correct and modify it in the relevant function pages of products or services. When the collection of your personal information by us has achieved the purpose of collection or is no longer necessary, or when you find that we have collected or processed your personal information in violation of laws, administrative regulations or the provisions of this Privacy Policy, you have the right to request us to delete relevant personal information. For personal information for which no correction or deletion channel is available to you for the time being, you can contact 【privacy@dlightek.com】 to request correction or deletion.

However, in some cases we may not approve your deletion request, for example, when you request us to delete transaction records and 【Bolo AI Keyboard】 is legally obligated to retain such transaction records to comply with applicable local laws. Please also note that if you request to delete your information from our products and services, due to applicable local laws and technical constraints, we may not immediately delete the corresponding information from the backup system, but we will securely store your personal information and prevent further processing until the backup system is updated, your information can be deleted or your information is anonymized.

6.3 Right to Withdraw ConsentTo realize the corresponding functions of our different products or services, we need necessary personal information in accordance with applicable local legal provisions. This is explained in "How We Collect and Use Your Personal Information" in this Privacy Policy. You may revoke the consent previously granted to us for specific purposes, including collection, use and/or disclosure of your personal information in our possession or control, by deleting information, disabling device functions, or requesting withdrawal of consent. You can contact us at 【privacy@dlightek.com】 to carry out relevant operations. We will process your request within a reasonable time after you send it, and will not collect, use and/or disclose your personal information according to your request thereafter.

If you withdraw your consent, you may not be able to continue to use part and/or all functions of 【Bolo AI Keyboard】 products and services. Withdrawal of your consent or authorization will not affect the validity of previous processing activities conducted by us based on your consent.

6.4 Right to ComplainYou have the right to contact us to make a complaint by sending an email to 【privacy@dlightek.com】. We will respond in a timely manner upon receipt of your complaint. If you are dissatisfied with our response, especially if our personal information processing behavior infringes your legitimate rights and interests, you may also file a complaint or report to the local competent personal data protection department, or institute legal proceedings in a competent court.

6.5 Right to Manage Privacy SettingsYou have the right to control your privacy settings, through which you can restrict our collection, use, disclosure or processing of your personal information. For example, you can choose to turn on or off the functions and permissions of "Location Access", "Camera", "Short Message"; you can also get more detailed information about device security status in "Settings". If you have previously agreed to enable corresponding permissions or agreed that we use your personal information based on the aforementioned business scenarios, you can turn it off through Settings > Application Management > Permission Management or contact us at 【privacy@dlightek.com】 to change your decision.

6.6 Right to Cancel Service or AccountYou may request to cancel your account through the cancellation path provided in this service or by contacting us at 【privacy@dlightek.com】. Please carefully make the account cancellation behavior. You acknowledge and understand that after you cancel your account, we will stop providing products and services based on such account together. Unless otherwise required by applicable laws of your region, we will also delete the corresponding personal data under your account. If you log in to this service through a third-party account, you must apply to the third party for account cancellation.

6.7 Rights Under Certain JurisdictionsPlease pay special attention: According to applicable laws of certain jurisdictions, you may have the following data subject rights

6.7.1 Right to restriction of processing. You have the right to request us to restrict the processing of your personal information. We will examine the reasons for your restriction request. If the reasons comply with applicable data protection laws, we will only process your personal information under the application of such laws and notify you before lifting the processing restriction.

6.7.2 Right to automated decision-making. You have the right to refuse information processing based on automatic decision-making, including performance analysis and other automatic processing that may have legal or similar effects on you.

6.7.3 Right to data portability. You have the right to request the transfer of your personal information to another data controller in a structured and commonly used format.

We reserve the right to refuse to process your request, and to reject certain of your requests under applicable exemptions or in compliance with applicable laws. For example, certain requests are clearly unfounded or obviously excessive, or require the disclosure of third-party information.

7. How We Handle Personal Information of Children

【Bolo AI Keyboard】 products and services are not provided to children under the age of 14 or the equivalent age stipulated by the laws of your jurisdiction (different countries or regions have different legal provisions on the age definition of children, we will define children mainly in accordance with the laws and regulations of the country or region where the specific business is located). We do not actively collect children's personal data, nor will we use children's personal information for marketing purposes. If you find that relevant children's information has been transmitted to us, please contact us at 【privacy@dlightek.com】 and we will delete such information as soon as possible. If we find that we have collected children's personal information, we will also try to delete such content as soon as possible.

8. Third-party Service Providers and Their Services

When you use 【Bolo AI Keyboard】 products or services (such as life services, online customer service services), you may receive website links to third parties other than us or content and services provided by third parties, and some third-party products or services may be carried out by means of SDK and others. You may choose whether to access or accept websites, products and services provided by third parties based on your own judgment. Our Privacy Policy does not apply to any products and services provided by third parties. Because we cannot effectively control third parties in substance, we are not responsible for the collection or processing of your personal information by such third parties. Before you submit any information to such third parties, please carefully understand the privacy policy of such third parties and pay attention to protecting your personal information.

9. Supplements and Updates to This Policy

We reserve the right to update or modify this Policy from time to time according to changes in our business, technology, applicable laws and operations. If this Policy is revised, we will post the latest policy here (this page) or notify you separately. Please pay regular attention to this page or the notices we send to you to keep abreast of updates to this Privacy Policy. Although this Privacy Policy may be adjusted, we will not weaken your rights under this Privacy Policy without your express consent.

When we collect other personal information from you or when we use or disclose your personal information for new purposes, we will obtain your explicit consent again in accordance with applicable laws. If you continue to use the products and services on the website, mobile devices and/or any other devices, you will be bound by the updated Privacy Policy.

The content of 【Bolo AI Keyboard】 products or services described in this Agreement may change according to the product type, system version or applicable local laws and regulations you use.

10. How to Contact Us

If you have any suggestions, questions or concerns about our Privacy Policy or our practices in personal information protection, please contact us through the following ways

Email: 【privacy@dlightek.com】 (Note: This email is only used to receive emails related to our Privacy Policy or our personal information protection.)

We will review your privacy or personal information request as soon as possible and respond within 15-30 days after verifying your user identity. If your request itself involves complex or major issues, we may require you to provide more information.

If you are dissatisfied with our response, especially when your legitimate rights and interests are infringed by us, you may seek solutions from the relevant data protection regulatory authorities in your jurisdiction. If you contact us with the above inquiries, we will provide you with information about possible applicable complaint channels according to your situation.

Thank you for taking the time to read our Privacy Policy!