Memories - Personal Information Collection List

Update Date:December 15, 2025

1.1 What Personal Information Do We Collect

https://whlmemories.com/what_info_do_we_collect

How We Collect and Use Your Personal Information

WHL Holding Limited (hereinafter referred to as "we") processes your personal information in accordance with applicable data protection laws and regulations, and employs security technologies to ensure data safety. We highly value your personal information and privacy, and are committed to protecting the privacy rights of every individual. Accordingly, we adhere to principles of legality, transparency, and data minimization.

For details on the personal information we collect, please refer to the Personal Information Collection List.

1.2 Purposes for Using Your Personal Information

1.2.1 Personal Information Management
To manage your personal data, we may need to collect information such as your email address and account used for login. You can fill in or modify this information in the “Profile” section. Choosing not to provide this information will not affect your ability to use device connectivity features.

To provide the Moments service, we will use your profile picture and nickname. These are used for publishing new content and posting comments.

1.2.2 Improving User Experience
To improve product quality and enhance user experience, we collect device identifiers (basic system information, device name, device identifiers, app logs, system usage information, device usage information, Android ID, Android Advertising ID, OAID), device usage information, system usage information, and wearable device usage information. This includes pages you open and buttons you click in the app, as well as the operation of app and device functions. This information is used to analyze and improve service and user experience. All data will be anonymized or de-identified and deleted after use.

The Android Advertising ID is only used for statistical analysis and product improvement, not for personalized advertising.

If issues occur while using the app, you can report them via the “Feedback” interface, including a description of the problem and contact information. To help us resolve issues promptly, we may collect system usage information, device hardware information, device identifiers (for anonymous analysis only), and basic system information. This data is used solely for troubleshooting and communication purposes, not for advertising or personalized recommendations. Logs and contact information you provide will be automatically deleted after the data retention period. Not providing this information may affect the efficiency of issue resolution but will not affect your ability to use other services.

To improve service quality, we may use anonymized device information for surveys. Survey content may involve personal information collection, which will be clearly stated, and your consent will be obtained. Participation is optional and will not affect normal service usage.

1.3 How We Use Your Personal Information

1.3.1 Account Login
To manage Memories data, account services are used for registration and login. Before using an account, please ensure you have read and agreed to the respective account’s privacy policy, including collection, use, and sharing of personal information. After login, we will use your account information (nickname and profile picture) and basic personal data (gender and date of birth) for display purposes in the app.

1.3.2 Memories Device Management
To manage your Memories devices (including wearable devices from WHL Holding Limited and affiliated companies, as well as third-party devices), we collect device identifiers (basic system information, device name, device identifiers, system logs, system usage information, device usage information, Android ID, Android Advertising ID, OAID, etc.), hardware information, device usage information, system information, and network information. This is to establish Bluetooth connections, manage device configurations, perform software updates, display data sources, and monitor device activation, while also enhancing network connectivity experience.

To support interaction between wearable devices and mobile phones, we may access calendar schedules and basic system information from your phone to your wearable device. We connect via Bluetooth or Wi-Fi to obtain device logs, location information, and device information (basic system info, device name, device identifiers, system logs, system usage info, device usage info, Android ID, Android Advertising ID, OAID, etc.). You may stop this data collection by disconnecting or unbinding the device.

If your wearable device supports weather forecasts, we will send approximate location information to weather service providers to retrieve weather information for your area. You can disable this feature at any time in the app’s device management settings.

When using our services, we may automatically collect detailed usage data for security audits, troubleshooting, and compliance purposes. This may include your login account, IP address, network environment, language used, access date and time, session duration, and refresh history.

1.3.3 Device Permission Usage

Storage Permission: Needed for sharing or logging in to accounts to read/write app data, images, videos, or other necessary intermediate data. You can disable this at any time without affecting other services.
Camera Permission: Required for connecting devices via QR code scanning. You may disable this without affecting other services.
Location Permission: Used for Bluetooth pairing, weather updates, and other location-related features. You may disable this without affecting other services.
Bluetooth Permission: Used together with location permission for battery information and low-power signal exchange.
Network Permission: Used for collecting app error logs, version updates, activation, and account login.
Device Information Access: Used to verify user device information (basic system info, device name, identifiers, logs, system and device usage info, Android ID, Android Advertising ID, OAID, etc.).
Microphone Permission and Voice Data: Audio is collected only when users actively trigger voice commands for real-time voice recognition. Voice recordings are not stored long-term or used for model training. You can disable this at any time without affecting other services.

1.4 How We Share, Transfer, and Publicly Disclose Your Personal Information

(1) Sharing
We do not share your personal information with other organizations or individuals, except in the following circumstances:

Sharing with explicit consent: We may share your personal information with third parties after obtaining your explicit consent. For example, if we engage a third party to provide products or services to you, we will only share the relevant information with your consent. If you refuse to provide such information, we may be unable to deliver the service.
Sharing under legal requirements: We may share your personal information to comply with laws and regulations, to resolve disputes, or at the request of administrative or judicial authorities acting within their lawful authority.
Sharing with affiliated companies: With your consent, we may share your personal information with our affiliated companies to provide services. Only necessary personal information will be shared, and it will be used only for the purposes stated in this Privacy Policy. If sensitive information is shared or if an affiliated company changes the purpose of use, we will seek your consent again.
Sharing with authorized partners: We may authorize partners to provide certain services or act on our behalf. Prior to sharing information, we will establish contractual or equivalent agreements outlining rights and obligations. Partners are only allowed to access information necessary to fulfill their responsibilities and cannot use it for other purposes.

(2) Transfer
We do not transfer your personal information to other companies, organizations, or individuals, except in the following circumstances:

Transfer with explicit consent: We may transfer your personal information after obtaining your explicit consent.
Transfer in the event of mergers, acquisitions, or bankruptcy: In such cases, we will ensure that the new company or organization that acquires your information continues to be bound by this privacy policy, or we will request their consent from you again.

(3) Public Disclosure
We will only publicly disclose your personal information in the following cases:

With your explicit consent;
As required by law, legal procedures, litigation, or mandatory requests from government authorities.

(4) Exceptions to Prior Consent for Sharing, Transfer, or Public Disclosure
In the following situations, your personal information may be shared, transferred, or disclosed without prior consent:

To fulfill legal obligations;
As required by law, or requested by administrative, judicial, or government authorities;
To protect the life, property, or other significant legal rights of you or others when obtaining consent is difficult;
Information voluntarily disclosed by you to the public;
As required under applicable laws and regulations;
Collection of personal information from publicly available sources, such as legitimate news reports or government disclosures.

According to the law, sharing or transferring de-identified personal information—where the recipient cannot restore or re-identify the data—does not constitute external sharing, transfer, or public disclosure. Retention and processing of such data do not require additional notice or consent.

How We Protect Your Personal Information

We take the security of personal data seriously and adopt industry-standard measures to prevent unauthorized access, disclosure, use, modification, damage, or loss. Reasonable measures include:

Using encryption to ensure confidentiality;
Implementing trusted protective mechanisms to prevent malicious attacks;
Deploying access control to ensure only authorized personnel access personal data;
Conducting security and privacy training to raise employee awareness of personal data protection.

We take reasonable steps to avoid collecting unrelated personal data. We retain personal data only as long as necessary to achieve the purposes described in this policy, unless legal requirements permit extended retention. While we strive to protect personal data, no security measure can guarantee absolute safety.

In the event of a personal information security incident, we will promptly inform you of:

The basic facts and potential impact of the incident;
Measures already taken or planned;
Recommendations for self-protection and risk mitigation;
Remedies available to you.

We will notify you via email, letter, phone, or push notifications. If individual notification is impractical, we will use reasonable methods to issue public announcements. We will also proactively report the incident to regulatory authorities as required.

Protection of Minors

For the purposes of this statement, “minors” are defined according to applicable laws in your jurisdiction. Minors may not create their own accounts without parental or guardian consent. If you are a minor, please have your parent or guardian read this Privacy Policy and the Rules on Children’s Personal Information Protection and Guardian Guidelines before using our services or providing personal information.

For minors using our services with parental consent, their personal information will only be used, shared, transferred, or disclosed when legally permitted, explicitly authorized by the parent or guardian, or necessary to protect the minor. If we discover that we have collected a minor’s personal information without verifiable parental consent, we will promptly delete such information.

How to Access or Modify Your Personal Data

To make it easier for you to access, correct, or delete your personal information and exercise your right to withdraw consent, we provide relevant operations within the product.

4.1 Accessing Personal Information
After installing and logging into the Memories app, you can view your nickname, profile picture, gender, date of birth, and other data on the “Profile” page.

4.2 Updating Personal Information
You can modify your nickname, profile picture, gender, and date of birth on the “Profile” page. Data automatically retrieved from your phone or Memories devices cannot be edited.

4.3 Account Deletion

4.3.1 Conditions for Account Deletion:
You can delete your account only if the following conditions are met:

a) No abnormal login in the past month;
b) No ongoing complaints or reports against the account;
c) No unused rights or benefits remaining (otherwise, deletion implies voluntary forfeiture);
d) You fully waive the right to retain or recover this data;
e) The account is not involved in any existing complaints, disputes, lawsuits, or regulatory investigations, and no foreseeable legal risks exist;
f) The account has no unfulfilled obligations under laws or regulations.

Deletion Process: Login to Memories APP → Profile → Settings → Account & Security → Delete Account. Your account information will be verified before deletion. Account deletion is irreversible.

4.3.2 Consequences of Account Deletion:

After deletion, you acknowledge and agree that:

a) You will no longer be able to perform any operations with this account;
b) You cannot log in again with this account;
c) All your data stored or used under this account will be permanently deleted and cannot be recovered;
d) Other consequences may arise that could impact your rights or cause losses.

Data Storage Locations and Retention Periods

Your personal information may be transferred to and stored on servers outside your country or region, including servers located in the Hong Kong Special Administrative Region of China. Data protection laws may vary across jurisdictions.

We retain your personal information only for as long as necessary to achieve the purposes described in this Privacy Policy, unless otherwise required or permitted by applicable laws and regulations. After the retention period expires, your personal information will be deleted or anonymized.

For your data security, your data is linked to your account. Memories data is transmitted in encrypted form and stored on the Memories cloud servers.

Questionnaire data obtained during surveys and device information collected during upgrade services (including system basic information, device name, device identifiers, system logs, system usage information, device usage information, Android ID, Android Advertising ID, OAID, etc.) will be retained for six (6) months from the date of collection, or will be securely deleted when you delete your account.
Personal information collected for statistical analysis and product improvement in user experience enhancement services will be retained for six (6) months from the date of collection.
Log information collected for analysis and troubleshooting through the “Feedback” service: logs are stored on WHL Holding Limited’s log servers for seven (7) days. Other data will be retained only as long as reasonably necessary to achieve the stated purpose.

How to Contact Us

Email: common@whlmemories.com
Company Address:
29th Floor, Entertainment Building
30 Queen's Road Central, Central

If you have any questions about this Privacy Policy or the protection of your personal information, we have established a dedicated personal information protection department (or personal information protection officer, email: common@whlmemories.com). You can contact them via the “Feedback” page, and we will respond as soon as possible.

If you are not satisfied with our response, especially if our handling of personal information has harmed your legal rights, you may pursue external remedies such as filing a lawsuit in a competent court, lodging a complaint with an industry self-regulatory association, or contacting the relevant government authorities. You may also contact us to learn about the applicable complaint channels.

WHL Holding Limited will always collect and use your information in accordance with this Privacy Policy.

Updates to This Policy

We reserve the right to update or modify this Privacy Policy from time to time. Any changes will be communicated to you through version updates.