iCard Club Privacy Policy

Date of Update: September 20, 2026
Effective Date: September 20, 2026

Hong Kong Manka Technology Limited (hereinafter referred to as "we"), as the operator of "iCard Club", attaches great importance to protecting the personal information and privacy of users (hereinafter referred to as "you").When you use the iCard Club application, the iCard Club website (specific URL: https://icard.club), as well as the software development kits (SDKs) and application programming interfaces (APIs) for third-party websites and applications (hereinafter referred to as the "iCard Club Platform"), we, on the basis of adhering to the "principle of informed consent", "principle of legitimacy and necessity", "principle of clear purpose", "principle of individual control", "principle of information quality" and "principle of security responsibility", further elaborate on how we collect, use, share and protect your personal information during your use of the iCard Club Platform.Please note that we may revise and update this policy from time to time in line with the real-time amendments to laws, regulations and relevant policies, and the relevant measures will change accordingly. Please agree to visit this page regularly to ensure that you are always aware of the latest version of this policy.

We hereby remind you that:

Before you use the iCard Club platform, please be sure to read this Privacy Policy carefully and fully understand the contents of each clause, including but not limited to the clauses that exempt or limit our liabilities. You acknowledge and confirm that by checking "Agree" to this Privacy Policy and using the iCard Club platform, you indicate your consent to our processing of your personal information in accordance with this Privacy Policy.

This Privacy Policy will help you understand the following:

I. How We Collect and Use Your Personal Information

(I) How we collect your personal information

During your use of iCard Club, we will collect and use the personal information that you proactively provide or that arises out of the need of the products/services when you use them, in accordance with laws and regulations and in adherence to the principles of legitimacy, legality and necessity. We collect your personal information in the following ways:

1. Complete the registration

When you register for an iCard Club account, we need to collect your mobile phone number (personal sensitive information, used to receive verification codes for personal identity matching), login password, and SMS verification code. If you log in via a third-party account, we will obtain relevant information under that third-party account in accordance with your authorization (including the nickname and profile picture of the third-party account, as well as other information you authorize, subject to what is displayed on the authorization login page of that third-party account).We collect the aforementioned information to help you complete the registration of your platform account and safeguard your account security. If you fail to provide such information, we will be unable to create an account for you and provide services to you properly.

2. Platform Services

2.1. When you use the platform services, in order to provide you with a continuous and consistent user experience, better display content for you, and understand the adaptability of the product to different hardware devices, we need to collect your device ID, device name, device type, language settings, operating system, software list, application version, login IP address, network access method, network quality data, mobile network information, network log information (operation logs, service logs), and storage devices.Meanwhile, to collect the aforementioned basic personal device information, we will apply for permissions to access your device information, including network access, phone status, mobile network information, and the permission to read/write external device storage (i. e. the permission to read/write SD card content and the permission to modify/delete SD card content).

2.2 When you use community features, share information, or receive shared information, we need to access your clipboard locally to read the passwords, share codes, links and contact information contained therein, so as to implement functions or services such as redirection, sharing and activity linkage. When you upload images or videos, we need to access SD card data locally, use your storage/album, camera and microphone permissions, and collect the video, image and text information and rough location information you provide.When you use the search function (including image and voice search), we will collect your search records, including search content (search terms, images, voice information), browsing records/time, search time/frequency, and apply for microphone permissions, camera permissions or the images you provide as necessary for the functions you use.

2.3 When you use community functions such as follow, like and comment, if you voluntarily fill in information or publish content, we will collect the videos, photos, posts, comments, likes, follow records, sharing information, browsing and search information you upload. You can delete the videos, photos, posts and comment content you published at any time. We need to verify the legality and compliance of the content you publish in the community to avoid the situation that the content you publish involves illegal acts or infringes on the legitimate rights and interests of third parties.You agree that, for the above-stated purposes, we will provide the content you post on the community, including images, texts and videos, to our service providers, who will review and label such content and then feed the results back to us; we will not transmit or share your personal information with the aforementioned service providers. We will only review the content you post, and you agree that we will decide whether and how to publish the images, texts, videos and other content you post on the community based on the review results.

We collect such information to provide you with the aforementioned functions, ensure your normal use of our services, maintain the proper operation of the platform's basic functions, optimize product performance, and enhance your product experience. If you refuse to provide the aforementioned permissions, you may be unable to use the relevant functions of our related products and services. Please understand that individual device information, log information and the like are information that cannot identify the identity of a specific natural person.If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, such non-personal information will be regarded as personal information during the period of such combined use. Unless otherwise authorized by you or stipulated by laws and regulations, we will conduct anonymization and de-identification processing on such personal information.

2.4 Ensure the security of networks and services

While you are using our services, in order to protect the legitimate rights and interests of users and the security of platform services, and to more accurately prevent fraud and safeguard account security, we will also collect your device identifiers (IMEI, IMSI, MAC address), installation identifiers, application IDs, IP Address, and access dates and times. Such information will be used to detect abnormal logins, abnormal automated behaviors, scan for cheat program, prevent cheating, conduct anti-crawling and other operations, so as to combat acts that undermine the fair environment or interfere with or disrupt the normal operation of platform services.Please understand that to dynamically detect whether there is abnormal login to your account, we may read the relevant information again each time you switch the iCard Club platform to the background or restart the program, and we will control the reading frequency within a reasonable range. If you do not provide the above information, you will not be able to use the platform services.

2.5 Customer Service

When you contact us or submit a customer service request to us (e. g., feedback/suggestions, complaints, appeals, consultations, dispute resolution), for the security of your account and system, we need you to provide necessary account information first and match it with your previous personal information to verify your user identity.Meanwhile, to facilitate contacting you, resolve customer service requests as soon as possible, and record the handling solutions and results of relevant requests, we also need to collect and use your contact information (mobile phone number, email address or other contact information you provide, which is sensitive personal information), city/region information where you are located, your communication information with us (including in the forms of text, images, audio and video, and call records), information you provide to prove relevant facts, and other necessary information related to customer service requests. If you initiate a customer service request for a specific order, we will also use your order information.If you refuse to authorize us to collect and use the aforementioned information, it will only result in your inability to use the aforementioned functions, but will not affect your use of other products or services we provide.

3. Personal information collected from other sources. We may obtain personal information about you from other sources, including third-party services and organizations. For example:(1) Authentication partners: If you access our services through third-party applications, such as app stores, third-party login services or social networking websites, we may obtain information about you from the personal information you obtain through these third-party applications. For example, we allow you to use registered single sign-on services to create accounts, or to link your platform accounts to these single sign-on services.You may decide which personal information we can obtain when you authorize the connection with the single sign-on service. (2) Publicly available data: We may collect your personal information from publicly available sources. (3) Social networks: We allow you to share personal information on social networks, or link your platform account with social networks. These social networks may automatically provide access to certain personal information they store about you (such as content you have viewed or liked, information about the advertisements you have seen or the links you have clicked, etc.).You can specify whether we can access your personal information through the privacy settings of each social network.

4. Other information. We may collect any personal information that you are willing to share with us.

(2) How we use your personal information

We will use the collected personal information in accordance with the provisions of this Policy and for the purpose of providing our services.

Please note that all personal information you provide when using the services we offer will continuously authorize us to use it during the period you use our services, unless you delete it or refuse our collection through system settings. When you cancel your account, we will stop using and delete your personal information.

We will compile statistics on the usage of the services we provide, and may share such statistical information with the public or third parties for the purposes of product development, service optimization and security assurance; however, such statistical information will not contain any of your personally identifiable information.

When we intend to use your personal information for other purposes not specified in this policy, or use the information collected for specific purposes for other purposes, we will seek your consent in advance in the form of your active ticking.

(3) Other Rules

Pursuant to relevant laws, regulations and national standards, we may collect and use your relevant personal information in the following circumstances without soliciting your authorization and consent:

is related to our performance of obligations under laws and regulations;

those directly related to national security and national defense security;

those directly related to public security, public health, and major public interests;

directly related to criminal investigation, prosecution, trial, and execution of judgments; and

It is necessary to protect the vital legitimate rights and interests such as the life and property of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the person concerned;

The involved personal information is disclosed to the general public by the personal information subject or guardian on their own initiative;

necessary for the conclusion and performance of a contract at the request of the personal information subject;

collecting personal information from legally and publicly disclosed information, such as through channels like legitimate news reports and government information disclosure;

necessary for maintaining the safe and stable operation of the provided products or services, such as detecting and handling faults of the products or services.

II. How We Store Your Personal Information

We will retain your personal information for the shortest retention period necessary for the purposes stated in this policy and as required by laws and regulations. Upon the expiration of the aforementioned period, we will delete or perform anonymization on your personal information.

Our servers are located in the US, and your personal information may be processed on servers outside your country. Data protection laws vary from country to country, with some countries offering stronger protection than others. Regardless of where your personal information is processed, we apply the same safeguards described in this policy. We also comply with certain legal frameworks related to data transfers.

III. How We Use Cookies and Similar Technologies

(I) How we use Cookies

1. By using Cookies, we provide users with a secure and personalized service experience. We and our third-party partners will store Cookies, Flash Cookies, or other local storage provided by your browser (or associated applications) on your computer or mobile device, which usually contain identifiers, site names, and some numbers and characters (collectively referred to as "Cookies"). We and our third-party partners may collect your information through Cookies and use it for the following purposes:

Security-related Cookies: Cookies help us ensure the secure and efficient operation of our products and services.

Recommendation Cookies: Cookies help us recommend, display and push content that may be of interest to you.

2. The collection and use of your information by third-party partners via Cookies are not governed by this Policy, but are subject to their own information protection statements, and we shall not be liable for the Cookies or similar technologies of such third parties.

3. If your browser or browser add-on services permit, you may modify the acceptance level for Cookies or reject our Cookies. For details, please refer to https://www.aboutcookies.org/ However, if you do so, it may affect your secure use of our products or services in certain cases. Meanwhile, you will still receive commodity or service information, though the relevance of such information to you will be reduced.

(2) How We Use Similar Technologies

In addition to Cookies, we also use other similar technologies such as embedded scripts on our website to enable the platform to create better content and serve customers. These elements are placed on multiple pages of this platform. When visitors access these pages, an anonymous notification related to this visit will be generated and may be processed by us or our suppliers. This technology is used in conjunction with the aforementioned cookies. If you do not wish to associate non-personally identifiable information with your access to these pages, please set your browser to disable the cookie function.

IV. How We Share, Transfer, and Disclose Your Personal Information Publicly

1. Entrusted Processing

We will entrust third-party service providers to process the personal information we collect about you, so as to enable them to provide us with products or technical support such as infrastructure technology, Data Analysis, advertisement delivery, and marketing decision-making. The aforementioned entrusted processing activities are subject to the purposes stated in this Policy, and we will supervise the aforementioned entrusted third-party service providers by means of contracts.

(2) Sharing

1. Obtain your explicit consent or authorization in advance, or you request us to share your personal information;

2. Disclose the information in accordance with the provisions of applicable laws and regulations, or as required by the mandatory requirements of the competent government departments;

3. Sharing with our affiliates: We may share your personal information with our affiliates; however, we will only share necessary personal information and such sharing is subject to the purposes stated in this policy; the affiliates will also adopt equivalent security measures in accordance with this policy to safeguard the security of your personal information;

4. Shared with our business partners. We may share your personal information with promotion channels and payment service providers on the premise of safeguarding your information security through measures such as encryption and anonymization. The purpose of our sharing of such information is to realize what is necessary for the provision of services; for example, we need to share your nickname, top-up information and the like with payment service providers to provide you with services.

(III) Transfer

We will not transfer your personal information to any company, organization or individual. However, in the event of a merger, acquisition, asset transfer or bankruptcy liquidation involving the transfer of personal information, we will inform you of the relevant circumstances, and require the new company or organization holding your personal information to continue to be bound by this policy; otherwise, we will require such company or organization to obtain your authorization and consent again.

(IV) Public Disclosure

Unless otherwise agreed in this Contract or explicitly stipulated by law, we will not publicly disclose your personal information.

Exception

In addition, according to relevant laws and national standards, we may share, transfer or publicly disclose personal information without prior authorization and consent from you in the following circumstances:

is related to our performance of obligations under laws and regulations;

those directly related to national security and national defense security;

those directly related to public security, public health, and major public interests;

directly related to criminal investigation, prosecution, trial, and sentence execution, etc. ;

Personal information disclosed to the general public by the data subject or their guardian on their own initiative;

Collecting personal information from legally and publicly disclosed information, such as through channels like legitimate news reports and government information disclosure.

Please note that the information you voluntarily share or even publicly disclose when using our services may involve your or others' personal information and even personal sensitive information. Please exercise caution when sharing or disclosing such information; if the information involved contains others' personal information, please obtain their consent before sharing or disclosing it.

Please be informed that in accordance with legal provisions, if we process personal information by adopting technical measures and other necessary measures to make it impossible for the data recipient to re-identify a specific individual or restore the data, the sharing, transfer and public disclosure of the data after the aforesaid processing shall not require separate notification to you or your consent.

V. How third-party products or services obtain your personal information

To provide you with richer and more comprehensive features, we use the following third-party software development kits (hereinafter referred to as "SDKs") to deliver services to you. When you use such third-party-provided services on our platform, you agree that your information may be directly collected and processed by the relevant third party. For the specific information collection and usage practices of the SDKs, please refer to the privacy policy or relevant statements of the SDK operator. Click Catalogue of Third-Party SDK Service Providers to view the details of the SDKs of our authorized partners that we have integrated.

The collection and processing of information by the aforementioned service providers shall be governed by their own privacy policies, and shall not be subject to this Policy. To the greatest extent possible to safeguard the security of your information, we recommend that you review the privacy terms of any third-party SDK-based services prior to use. To protect your legitimate rights and interests, if you find such SDKs or other similar applications to be risky, we advise you to immediately terminate the relevant operations and contact us in a timely manner.

VI. How We Protect Your Personal Information

We attach great importance to the security of personal information and take all reasonable and practicable measures to protect your personal information:

We have adopted industry-standard data protection technologies and management measures, such as network isolation, data encryption, and employee access control, to prevent data from being unauthorizedly accessed, disclosed, tampered with, lost or destroyed.

Please note that while we will endeavor to ensure or guarantee the security of any information you send to us, the internet environment is not 100% secure, and we shall not be liable for any risks or losses arising therefrom or in connection therewith.

In the event of an unfortunate personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impacts of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and mitigate risks, and remedial measures for you, etc. We will promptly inform you of the relevant information about the incident via methods such as application push, email, short message, and telephone. When it is difficult to notify each personal information subject one by one, we will release announcements through reasonable and effective means. Meanwhile, we will also proactively report the disposal of the personal information security incident in accordance with the requirements of the regulatory authorities.

VII. How you manage your personal information

During your use of this product/service, you may contact us via the prompts on the corresponding pages or the methods specified in this privacy policy to access, correct, and delete your personal information, as well as exercise the rights to change the scope of authorized consent and deregister your account, and your feedback will be addressed in a timely manner.

(I) Access and correction of your personal information

If you wish to access or correct your personal information, you may contact us through the channels specified in this Privacy Policy, and we will respond to your request promptly.

(2) Delete your personal information

In the following circumstances, you may submit a request to us for the deletion of personal information through the methods specified in this Privacy Policy:

We collect or use personal information in violation of laws, administrative regulations or the agreement with you;

If we share or transfer your personal information with third parties in violation of laws, administrative regulations or the agreement with you, we will immediately stop such sharing and transfer, and notify the third party to delete it in a timely manner;

If we publicly disclose your personal information in violation of laws, administrative regulations or the agreement with you, we will immediately stop such public disclosure and issue a notice requiring the relevant recipient to delete the corresponding information;

when you no longer use our products or services, cancel your account, or we terminate the provision of services and our business operations.

(III) Changing the scope of your authorized consent

You may contact us through the device permission settings or the methods specified in this Privacy Policy to adjust the scope of your consent or withdraw your authorization.

Please understand that this game may require the enabling of certain permissions and the collection of necessary personal information to function properly. When you withdraw your consent, we will be unable to continue providing you with the services corresponding to the withdrawn consent, but this will not affect the personal information processing services that were carried out based on your authorization prior to the withdrawal.

(IV) Account Cancellation

If you wish to deregister your account, you may contact us via the methods specified in this Privacy Policy, and we will respond to your request in a timely manner.

Your cancellation of the aforementioned account is irreversible. We will cease providing you with products or services, stop collecting your personal information, and delete the personal information related to your account or conduct anonymization in accordance with your request.

(V) Respond to your above-mentioned request

If you are unable to exercise your rights in the manner described above, you may contact us via the contact details specified in this Privacy Policy. For security purposes, you may be required to submit a written request or otherwise verify your identity. We may first ask you to verify your identity before processing your request.

We will not charge fees in principle for your reasonable requests, but for requests that are repeated multiple times or exceed reasonable limits, we will charge certain costs as appropriate. We may reject requests that are repeated without cause, require excessive technical means, pose risks to the legitimate rights and interests of others, or are highly impractical.

(VI) Exceptions to Response Scenarios

We will be unable to comply with your request in the following circumstances:

related to our performance of obligations under laws and regulations;

that are directly related to national security and national defense security;

that are directly related to public security, public health and major public interests;

directly related to criminal investigation, prosecution, trial, judgment enforcement and other such matters;

We have sufficient evidence to prove that the subject of personal information has subjective malice or abuses their rights;

where it is necessary to safeguard the vital legitimate rights and interests such as the life and property of the personal information subject or other individuals, but it is difficult to obtain the consent of the person concerned;

Responding to the request of the personal information subject would cause serious damage to the legitimate rights and interests of the personal information subject or other individuals or organizations;

Where trade secrets are involved.

VIII. How we handle minors' personal information

(I) Service Object Oriented

This Service is primarily intended for adults. If you are a minor under the age of 18, you must carefully read this Policy under the accompaniment and guidance of your parents or other guardians before registering for, using this Service, or submitting any personal information to us, and use this product or service only with the explicit consent of your parents or guardians.

(II) Special Reminder for Guardians

If you are the guardian of a minor, please pay attention to whether the minor under your guardianship uses this service after obtaining your authorization and consent. If you find that a minor has submitted personal information to us without your consent, or have any questions about the processing of personal information in relation to this service, please contact us through the contact information set out in this policy.

(III) Special Protection for Children (under 13/16 years of age)

We will not intentionally collect or induce the collection of personal information of children under the age of 13 (or the age of 16 as stipulated by the laws of your country/region, such as in the European Union). If we discover that personal information of a child has been collected without prior verifiable parental/guardian consent, we will take measures as soon as possible to delete the relevant data and cancel the corresponding account.

IX. How We Update This Privacy Policy

Our privacy policy may be updated from time to time. We will post any changes to this privacy policy on this page. For material changes, we will also provide more prominent notices (which may include specific explanations of the changes to the privacy policy via special prompts on our browsing pages). We will not reduce your rights under this privacy policy without your explicit consent.

Material changes referred to in this privacy policy include but are not limited to: major changes to our service model; changes to the main recipients of personal information sharing, transfer or public disclosure; major changes to your rights in respect of personal information processing and the way to exercise such rights; changes to our contact information and complaint channels; and cases where the personal information security impact assessment report indicates a high risk.

We will also archive previous versions of this Privacy Policy for your reference.

X. How to Contact Us

1. If you have any questions regarding this policy or the protection of personal information, we have set up a dedicated customer service channel for you. You may contact us via email at service@icard.club with your inquiries, comments or suggestions, and we will respond to or address your questions, comments and suggestions in a timely manner.

2. As a general rule, we will reply within 15 working days. In addition, we will be unable to respond to your request under the following circumstances related to personal information:

2.1 Is related to our performance of obligations stipulated by laws and regulations;

2.2 Those directly related to national security and national defense security;

2.3 Those directly related to public security, public health, and major public interests;

2.4 being directly related to criminal investigation, prosecution, trial and judgment enforcement, etc. ;

2.5 There is sufficient evidence to prove that you have subjective malicious intent or abuse of rights;

2.6 It is necessary to protect the vital and legitimate rights and interests such as the life and property of you or other individuals, but it is difficult to obtain the authorization and consent of the person concerned in advance;

2.7 Responding to your request would cause serious harm to the legitimate rights and interests of you or other individuals or organizations;

2.8 Involving trade secrets.

If you are not satisfied with our response, in particular if our processing of personal information infringes upon your legitimate rights and interests, any relevant dispute shall be submitted to the Hong Kong International Arbitration Centre (HKIAC) for arbitration in accordance with the arbitration rules in force at the time of the submission of the arbitration notice, and the place of arbitration shall be Hong Kong. The arbitral award shall be final and binding on both you and us.

If the data you provide contains personal data of other users, you must ensure that you have obtained legal authorization before providing such personal data to us.

3. In the event of any conflict between the English version of this Privacy Policy and versions in other languages (if any), the English version shall prevail.

XI. Jurisdiction-Specific Addenda

1. California Residents of the US If you are located in the state of California in the US, pursuant to the CCPA/CPRA:

Information Collection: Over the past 12 months, we have only collected your identifiers (such as IP address, device identifier), online activity information (such as page browsing history), customer service information and security-related information for the purposes of providing information services and ensuring the secure operation of products.

No sale or sharing: We will never sell your personal information, nor will we share your personal information for cross-context behavioral advertising.

Your rights: You have the Right to be informed, Right of access, the right to erasure and the right not to be discriminated against.

2. Supplementary Statement for Residents of the European Economic Area (EEA) and the United Kingdom (GDPR Notice)

If you reside in the European Economic Area or the United Kingdom, you have the following additional rights under the General Data Protection Regulation (GDPR):

Legal basis for data processing: We process your device data and log information on the grounds of "being necessary for the performance of services" and "legitimate interests in improving products and displaying relevant content".

Cross-border transfer: Your information may be transferred to servers outside your country/region for processing, and we will ensure data security through legal mechanisms such as signing Standard Contractual Clauses (SCCs).

Data Subject Rights: You have the right to access, rectify, and erase your personal data, to restrict or object to the relevant data processing, and to lodge a complaint with the data protection authority (DPA) in your jurisdiction. To exercise your rights, please contact us via the contact details specified in this policy.

3. Contact Us

If you have any questions about this Privacy Policy or the supplementary terms for a specific region, please contact us via the following method: Email: 【service@icard.club】.