Last Updated: Feburary 28th, 2023 Effective Date: Feburary 28th, 2023

INTRODUCTION

Xiaohongshu (“We”) respect and protect the personal information and privacy of all users of Xiaohongshu Services. In order to provide you with more accurate and personalized services and a more secure Internet environment at the same time, we have established Xiaohongshu User Privacy Policy ("Privacy Policy") to clarify our principles in collecting/using/providing personal information and further elaborate your rights in respect of your personal information in accordance with the Cybersecurity Law of the People's Republic of China, the Law on the Protection of Personal Information of the People's Republic of China, the Civil Code of the People's Republic of China, the Information Security Technology – Personal Information Security Specification and other applicable laws, regulations and technical standards.

This Privacy Policy relates to your use of Xiaohongshu App and related websites (collectively, “Xiaohongshu Services”). When you download, install, launch, browse, register, log in or use Xiaohongshu Services, we will process and protect your personal information in accordance with this Privacy Policy. We will try to explain the technical terminology involved in this Privacy Policy in concise terms so that you can easily understand it. Please focus on the provisions of this Privacy Policy which (may) be material to your rights and interests in bold font to make a distinction therefrom.

When using the Xiaohongshu Services, the account you registered in Xiaohongshu App can simultaneously log in the “Xiaohongshu Video”(tentative, the specific name operating on line shall prevail, hereinafter referred to as “Xiaohongshu Video”) and other different versions of applications and obtain the services and use the functions related to Xiaohongshu Video, except for some cases of using third-party account registration. You shall be bound by the user service agreement, privacy policy and the terms of the relevant agreement of Xiaohongshu Video when you use the account to log in and use Xiaohongshu Video.

Xiaohongshu particularly wishes to draw the attention of those under 18 years of age (especially those under 13 years of age) and their guardians. Please read carefully the special section (in bold) for the personal information protection of minors.

Please read carefully and fully understand this Privacy Policy before using/continuing to use Xiaohongshu Services and, if necessary, make appropriate choices in accordance with the guidelines in this Privacy Policy. If you do not agree to this Privacy Policy, Xiaohongshu Services may not function properly or achieve the results we intend to provide, in which case you should immediately stop accessing/using Xiaohongshu Services. Your use or continued use of Xiaohongshu Services means that you fully understand and agree to this Privacy Policy (including any updates) in its entirety.

About Us

The operators of Xiaohongshu Service are Xingyin Information Technology (Shanghai) Co., Ltd. and its affiliates.

The registered address is Rooms C201, C202, C203, C204, C205, C206 and C207, C/F,Fuxing SOHO Plaza, No. 368, Madang Road, Huangpu District, Shanghai.

1. How We Collect Your Personal Information

2. How We Use Your Personal Information and Legal Basis of Personal Information Processing

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

4. How We Store and Protect Your Personal Information

5. How You Manage Your Personal Information

6. How You Cancel Your Account

7. Special Instructions on Products and/or Services Provided by Third Parties

8. How We Use Cookie and Other Similar Technologies

9. Protection of Minors

10. How We Update the Privacy Policy

11. How to Contact Us

12. Miscellaneous

I. How We Collect Your Personal Information

You understand and agree that:

Xiaohongshu is a lifestyle platform for young people. Our mission is inspiring lives to share and discover the wonders of the world through short videos, pictures, texts and other forms to record your lives, share your lifestyles and form interactions based on interests. In this Privacy Policy, we will explain in order to you the scope, purposes and methods of our personal information collection, and possible consequences of refusing to provide personal information. Please be aware that you can still use other functions of Xiaohongshu Services if you refuse to provide the corresponding information necessary for the implementation of such function.

(I) Personal Information You Provided Directly

1. Mobile Number

1.1 When you register and log in, if you use the one-click login function, based on our cooperation with the telecom operators, we will collect your mobile phone number and network operator information to provide you with fast and convenient log in service.

1.2 If you log in with a third party account, we will collect your account information with the third party platform to provide you with fast and convenient log in service. Such information may include third-party app install status, Facebook ID, Wechat ID, Weibo ID, Apple ID, nickname, and profile picture (specifically subject to your authorized scope). We may collect such information from third parties, including our industry peers, such as other online platforms and technology companies. These third parties collect your information when you visit their site or app or use their services, or through other businesses or organizations they work with. We require them to have the right to collect, use and share your information before giving it to us.

1.3 If you log in with a third party account, we will collect your mobile phone number to complete real name authentication before you start using posting, comment and other features and services requiring real name authentication. Please consider carefully before providing this information. If you refuse to provide this information, you might not be able to use the required features.

2. Interest

To help you complete the registration process, we will also collect your interest and provide you with an initial service of Xiaohongshu App.

3. Account Information

You may complete your account information by filling in or changing, based on your own needs, the avatar picture, name, gender, birthday, occupation, region, school, profile and dressing information. However, refusal to provide such information will not affect your use of Xiaohongshu App.

4. Content

When you use the Post, Comment, Like, Favorite, or Share functions, your text, photo, video, audio, comment, Like, Favorite, or Share records are stored on our servers, because storage is necessary for this function. This information will be stored encrypted, and you can delete it at any time.

5. Real Name Authentication Information

5.1 When you apply for becoming an authenticated user using the identity authentication, we will collect your identity information, including your name, ID number, or photo(s) and facial recognition information to verify your identity. If you refuse to provide such information, this will not affect the normal use of other functions of Xiaohongshu App.

5.2 When you apply for the Account Retrieval, we will collect your identity information, including your name, ID number, or photo(s) and facial recognition information to verify your identity and retrieve your account. If you refuse to provide such information, this will not affect the normal use of other functions of Xiaohongshu App.

5.3 When you apply for the Live function, as required by laws and regulations, we will collect your identity information, including your name, ID number, or photo(s) and facial recognition information to verify your identity. If you refuse to provide such information, this will not affect the normal use of other functions of Xiaohongshu App.

5.4 When you apply for the Product Cooperation function, as required by laws and regulations, we will collect your identity information, including your name, ID number, or photo(s) and facial recognition information to verify your identity. In order to help you successfully complete the product cooperation, we will collect your mobile phone number or Wechat number. If You refuse to provide such information, this will not affect the normal use of other functions of Xiaohongshu App.

5.5 When you apply for the Brand Cooperation function, for the purpose of verifying your identity and determining whether you meet the access conditions to use Brand Cooperation function, we will collect your name, ID number, or photo(s) . If you refuse to provide such information, this will not affect the normal use of other functions of Xiaohongshu App.

5.6 When you place an order for goods/services through a cross-border transaction, you need to provide your name, ID Number and the front and back photos of the ID card to complete customs clearance.

5.7 When you apply for the Digital Collections function, we will collect your identity information, including your name, ID number, or photo(s) and facial recognition information to verify your identity.

5.8 When you use our Skin Test or Makeup Trial function, we need to collect your storage (photo albums, media and other documents), camera permission or face recognition information after obtaining your individual consent through the pop-up window in order to provide the service to you. But we will not store your facial recognition information after providing the Skin Test and Makeup Trial functions. If you refuse to provide the above facial recognition information, you will not be able to experience the Skin Test function and Makeup Trial function. However, this will not affect the normal use of other functions of Xiaohongshu App. Please be aware that the above facial recognition information directly relates to your personal and property safety, so you should consider carefully when providing the above facial recognition information to us. We will only collect and process the above facial recognition information for the purpose of providing the Skin Test function and Makeup Trial function, and the processing of personal information will only affect the result of the Skin Test function and Makeup test function.

6. Personal Education and Work Information

When you apply for the Brand Cooperation function, for the purpose of verifying your identity and determining whether you meet the access conditions to use Brand Cooperation function, we will collect your occupation and educational background. If you refuse to provide such information, this will not affect the normal use of other functions of Xiaohongshu App.

7. Personal Property Information

When you apply for the Brand Cooperation function, for the purpose of verifying your identity and determining whether you meet the access conditions to use Brand Cooperation function, we will collect your income. If you refuse to provide such information, this will not affect the normal use of other functions of Xiaohongshu App.

8. Payment Information

8.1 You can order goods/services on Xiaohongshu Mall. In order to help you successfully complete the transaction, ensure the security of your transaction, inquire about order information, and provide logistics services, when you place an order, we will collect your transaction information, order number, order time, fee and payment method.

8.2 You can purchase goods/services and Xiaohongshu membership services at Xiaohongshu App. During the process of using these functions, you may need to pay. During the payment process, we will collect your third-party payment accounts (Alipay account, WeChat account, UnionPay account and related accounts).

9. Contact Information

You can order goods/services on Xiaohongshu Mall. In order to help you successfully complete the transaction, ensure the security of your transaction, inquire about order information, and provide logistics services, when you place an order, we will collect your name, address, contact number, and logistics information.

10. Communication Records of Customer Service

When you contact our customer service staff or make an after-sales application for Xiaohongshu Services, we will collect the communication records between you and the customer service staff. For the security of your account and system, we need you to provide relevant personal information that matches the personal information you provided before to verify your user identity. After successful verification, we need to collect your communication information with us (account information, telephone recordings, order information, picture/video/text information, and related information you provide to prove relevant facts) and your contact information to solve your problems and improve Xiaohongshu Services as soon as possible. At the same time, we may take the initiative to contact you by phone, text message, in-site letter, and other related methods to communicate your problems arising from using Xiaohongshu Services.

To ensure the service experience and deal with the service disputes, the call between you and the customer service staff needs to be recorded. The rules for the collection and use of the above information are as follows:

10.1 If you have a dispute with the platform or merchant when you use the Xiaohongshu Services, we can retrieve and use the call recording as a reference for resolving disputes.

10.2 In order to provide you with customer service and after-sales service, we store your call recordings in the third-party customer service system, and we will ensure that third parties cannot access your call recordings through agreement constraints. We will not provide the call recording to anyone (including the caller or the called party), except under the following circumstances: a. where the call recording is obtained by competent authority in accordance with legal procedures; or b. where the party whose call is recorded obtain the recording in accordance with the legal documents issued by judicial authority.

(II) Personal Information Automatically Collected

1. Account Information

1.1 In order to verify your identity and determine whether you meet the access conditions for using the brand cooperation function, we need to collect your Xiaohongshu account information. If you refuse to provide such information, this will not affect the normal use of other functions of Xiaohongshu App.

1.2 To save time when you fill in forms or order information in Xiaohongshu App, we will automatically fill in the form based on your name, gender (if any), mobile phone number and region (if any) you provide to us when you register or make purchases.

1.3 To show you personalized content or ensure you to receive more appropriate content, we need to collect the personal information (including gender and date of birth) you provided in Xiaohongshu App. If you are not interested in the push content or want to reduce certain types of push content, you can long press on the note and click “Not Interested”. You may choose to turn off the push content by going to [Me] - click on the upper left corner – [Settings] – [Privacy Settings] – [Personalization Options].

2. Browsing Records and Operation Records

2.1 To show you personalized content or ensure you to receive more appropriate content, We need to collect records of your search/play/display recommended content and audio and video playback records in Xiaohongshu App. If you are not interested in the push content or want to reduce certain types of push content, you can long press on the note and click “Not Interested”. You may choose to turn off the push content by going to [Me] - click on the upper left corner – [Settings] – [Privacy Settings] – [Personalization Options].

2.2 When you use the search function, we will collect your search keywords, browsing records, access time, comments and interaction records. Collecting such information allows us to provide you with the content you need and services you may be more interested in, and in the meantime, improve our Xiaohongshu Services.

2.3 If you share or be shared information or participate in activities, we need to access your clipboard to obtain the token, sharing code or link contained therein, so that you may jump, share or activity linkage functions or services.

2.4 To provide you with the product information display, search and push services more conveniently tailored to your personalized needs, based on your device information (including the device information and mobile app list information as set forth in Article 6) as well as your browsing and usage data and purchase history when you use the Xiaohongshu App, we generate indirect population portraits based on the feature tags for display, push information and possible commercial advertisements to you. (Please understand the device information alone cannot identify a particular natural person. If we combine such non-personal information with other information to identify a specific person, or use it in combination with personal information, such non-personal information will be considered personal information during the combined use, unless authorized by you or unless otherwise provided by laws and regulations, we will anonymize such personal information. )

3. Contact Information

With respect to your contact information (telephone, email and other contact information) provided by you during the process of using Xiaohongshu Services, we may provide you with the services, functions or activities and related commercial information that may be interesting to you by means of text messages and calls. We strive to ensure your browsing experience. If you do not want to receive commercial ads we send you, you can unsubscribe or close the subscription by another method provided. You can also contact us directly to unsubscribe.

4. Content

When you follow the accounts that you are interested in, browse, comment, like, collect or share content, we will collect the information of the accounts that you follow and the aforesaid notes and show you the content published by the accounts that you follow; in the meantime, the content that you like or collect will be shown to your fans. You can set the collected content to be visible only to yourself or open it in [Me] - [Collects] - [Collects Boards], setting the board as private information.

5. Photo/Video Information

5.1To speed up video uploading, enrich publishing features and optimize your experience, we will temporarily upload your edited video to the server before you click “publish notes”. If you quit editing page, or if you don't publish notes for other reasons, we will delete the video immediately. You can turn off this feature in [Me] – [Settings] – [General Settings]- [Not Allow Upload Videos in Advance].

5.2 When you choose to use QR code to add friends, we need to ask you for camera permission. Camera permission is a sensitive permission. Therefore, refusing to provide camera permission will only make you unable to add friends by QR code, it will not affect you using other functions.

6. Technical Information

6.1To ensure the safe operation of software and services, prevent your personal information from being illegally obtained, prevent fraud and protect the account security, we will collect your device information [Including: device model, device name, SIM card serial number, device unique identifier (Including: IMEI, IMSI, Android ID, IDFA, OAID)], browser type and setting, language setting, sensor, operating system and application version, network device hardware address (MAC Address), login IP Address, way of accessing network, network quality data, mobile network information (including operator name), product version number, storage (albums, media and other files) and software usage record information. If you do not agree for us to collect the above information, the risk control verification might not be completed. Please understand, in order to dynamically detect if there is any abnormal login in your account, every time you switch Xiaohongshu App to background or restart the application, we will read the reading frequency in a reasonable range. In order to maintain the network security and protect the good ecology, the region information corresponding to your IP address will be displayed on your profile page, note publishing page and comments. The domestic region information is displayed as province (region, city) information, and the overseas region information is displayed as country (region) information. The specific information is subject to the data of the network operator.

6.2 To ensure that when you use the services in Xiaohongshu App, you can communicate with the background servers instantly and receive personalized content pushed in a timely manner, we will i) obtain and use your power-on broadcast permission from you to launch the mobile application of Xiaohongshu or its affiliates, ii) use a third party message push service to generate an identification ID for you to distinguish the uniqueness of your device, iii) read the status of your mobile phone to determine whether the Xiaohongshu App is in the foreground or background.

7. Transaction Information

In order to facilitate you to check your virtual property and minimize possible risks, [Wallet] will record your charge, balance and usage.

8. Address Book Information

8.1 When you use the function of recommending address book friends or discovering friends on your own initiative, with your express consent, we will collect your address book information and use it to show friends in the address book to you. Your friends will also be able to see your use of the Xiaohongshu Services. If you do not want to be recommended, you can choose to turn off in [Me] - click on the upper left corner- [Settings] - [Privacy Settings] - [Hide Me from People I May Know]. Address book information is personal sensitive information. Refusal to provide such information will only prevent you from using the above functions, without affecting your normal use of Xiaohongshu Services.

8.2 If you need to edit your receipt information when you purchase goods or services, we need to request permission to access your address book. Address book permission is sensitive. If you refuse to provide it, you will not be able to edit your receipt information through your address book. However, it will not affect the use of other functions.

9. Location

9.1To ensure the secure operation of software and services, prevent your personal information from being obtained illegally, prevent fraud more accurately and protect the security of your account, we will collect your location information. If you do not consent to our collection of the above information, we may not complete the risk control verification. Please understand that in order to dynamically detect whether there are abnormal logins in your account, every time you switch Xiaohongshu App to background or restart the application, we may collect the location information again. We will keep the reading frequency within a reasonable range.

9.2 When you turn on the device location function and use the location-based services provided by Xiaohongshu App(including content recommendation, content publishing, shopping receiving information editing, and data editing), we need to obtain your separate consent from you through the pop-ups to collect your location information. Location is sensitive personal information. If you refuse to provide such information, you will not be able to use the relevant location-based services mentioned above, provided that such refusal shall not affect your normal use of other functions of the Xiaohongshu App.

10. Summary of Device Permission Invocation

The following is a summary of the main permissions that we will ask during the process of providing services. You can choose to turn off some or all permissions in the settings of the device. The display and turn off permissions might be different in different devices. For details, please refer to the device and system developer's instructions or guidelines:

![device and system developer's instructions or guidelines](https://picasso-static.xiaohongshu.com/fe-platform/69340d0e496b1168dc30f4e01f023356e42552a9.jpeg)

(III) Personal Information Collected from Third Parties

If you use a third party platform account to log in, after you explicitly authorize the account binding, the third party platform will provide your avatar, nickname, region (if any), gender (if any) and friend information (for Weibo platform) used on that platform to us so that you can directly log in and use Xiaohongshu App.

If you don't want to be recommended to Weibo friends, you can choose to turn it off in [Me] - [Settings] - [Privacy Settings] - [Hide Me from People I May Know].

II. How We Use Your Personal Information and Legal Basis of Personal Information Processing

(I) Purposes of the use of personal information

To provide, optimize and improve our services to you, we use your personal information for the following purposes:

1. Account registration and login;

2. To provide Xiaohongshu Services to you:

2.1 Information browsing, publishing, liking, collecting and sharing;

2.2 Safe operation and risk control verification;

2.3 Search;

2.4 Locating;

2.5 Interactive functions and services;

2.6 Purchasing, inquiry and use virtual properties;

2.7 Identity verification and account retrieval;

2.8 Product purchase function;

2.9 Application for digital collections;

2.10 Customer service and after-sales service;

2.11 Payment;

2.12 Pre-filling of information;

2.13 Skin test and makeup trial function;

2.14 Personalized content display, search and push;

2.15 Clipboard.

(II) Legal Basis of Personal Information Processing

In order to assist you in using Xiaohongshu Services, we will process your personal information to the extent necessary to achieve the personal information processing purposes described above for the Xiaohongshu Services described in this Privacy Policy or for any other purpose disclosed to you by us at the time your information is collected or with your consent.

In accordance with applicable laws (including but not limited to the General Data Protection Regulation), we process your personal information on the legal basis that:

1. Necessary for the conclusion and performance of a contract to which you are a party, or for the implementation of human resources management in accordance with labor rules and regulations formulated in accordance with applicable law and a collective contract concluded in accordance with applicable laws;

1.1 Account registration and login;

1.2 Provide the basic functions of Xiaohongshu Services;

2. Necessary for the performance of statutory duties or obligations;

3. To protect the legitimate interests of you or other natural persons:

3.1 Safe operation and risk control verification;

3.2 nteractive functions and services;

3.3 Personalized content display, search and push;

4. To Perform tasks in the public interest:

4.1 Necessary for responding to a public health emergency, or to protect the life, health and property safety of natural persons in an emergency;

4.2 Processing personal information within a reasonable scope to carry out news reporting and supervision by public opinion for the public interest;

5. Your Consent

In addition to the above legal basis of personal information processing, we may, with your consent, collect and use the personal information provided voluntarily by you during your use of our services, automatically collected as a result of your use of Xiaohongshu Services, or collected from third parties for the purposes of using the personal information as described in this Privacy Policy. If we use your personal information for purposes not specified in this Privacy Policy, or use the information that we have collected for specific purposes other than those set out in this Privacy Policy, we will reasonably notify you and obtain your consent again before such use. You may review details at [Me] – [Settings] – [Personal Information List].

You may withdraw your consent at any time. You may contact us via the methods disclosed by us in Section 11 of this Privacy Policy.

6. Other legal basis

Subject to applicable laws and regulations, we may process your personal information without your consent.

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

1. Sharing:

We will not share your personal information with any company, organization or individual, except in one or more of the following circumstances:

（1）your prior consent has been obtained;

（2）any such request has been made by you;

（3）it’s necessary to share with our business partners:

You understand and acknowledge that, in order to provide you with better products and services, we may authorize our business partners to provide you with certain services. In such cases, we may share certain of your personal information with our business partners in order to provide better customer service and user experience. Please note that we will only share your personal information for legal, proper, necessary, specific and express purposes, and only the personal information necessary for the provision of the services. We will conduct security assessment and processing of the export form, flow and use of information and data to protect data security. In the meantime, we will strictly supervise and manage our business partners, and will immediately cease cooperation with them and will hold them liable if they are found to have processed personal information in violation of regulations.

At present, our business partners include the following types, please refer to the Third Party Information Sharing List for details:

A. Third-party merchants on our platform: In order to help you purchase products or services or provide you with after-sale services, third-party merchants on our platform will share your order and information related to your transaction with us.

B. Third-party logistics service providers: After you successfully place an order, if products need to be delivered by a third party, to complete the delivery and delivery to you in an accurate and safe manner, third-party logistics companies will inevitably obtain relevant delivery information from us about you in the process of delivery and delivery. We promise to you that we will use our best efforts to protect the security of your personal information, and we will strictly require third-party logistics companies to keep your personal information confidential, to be known and used only for the purpose of delivery, and shall not disclose or use it for any other purposes.

C. Advertising and statistical analysis partners: In order to assist with advertising or decision advice, improve effective reaching of advertising and further understand user needs, we may share de-identified equipment information or statistical information with partners who entrust us with information promotion and advertising services or statistical analysis partners, which are difficult or impossible to link to your real identity. Please be aware that, for the purpose of your information security, we are only working with partners who have signed strict data security confidentiality agreement.

D. Content review service providers: In order to ensure the security and safety of the contents published by users on the Internet information platform, we may share the information published by you on the platform with third-party content review service providers entrusted by us.

E. Real name authentication review service providers: When you conduct real name authentication or use the account retrivial function, we will share your personal information with third-party review service providers, so that you can successfully retrieve your account.

F. Skin test function service providers: The specific skin test function is provided by third-party service providers cooperating with Xiaohongshu. When you use the function, we will share your personal information provided by you to the platform based on the function with third-party service providers, so that you can successfully experience the function.

G. Third-party applets: When you use third-party applets, without your consent, we will not share your personal information with these developers and operators. When you use applets, they may use the relevant system permissions authorized by you, and you can withdraw such authorization in the corresponding applets.

H. Digital collections technology service providers: When you use the digital collections function, we will share your personal information provided by you to the platform with third-party technology service providers, so that you can successfully experience the function.

I. Other business partners: Partners who entrust us with promotion and advertising service. You authorize us to share the indirect user portraits formed by using the collection of your relevant information with our partners, who entrust us with promotion and advertising service, in order to assist them with advertising or decision-making advice, to improve the effective reaching rate of advertising and to further understand user needs. However, we promise that we will not share your personal information that may identify you with them without your consent.

J. Cooperating third-party SDK service providers: When you use the functions in Xiaohongshu App provided by a third party, we may access the software development kit (SDK) provided by the third party to achieve relevant functions. At this time, third-party SDK service providers may collect relevant personal information from you, please refer to the Third-Party Information Sharing List for details. We will exercise the duty of care to strictly monitor the security of such third-party SDK to protect the security of personal information:

a. one-click login function: in order to provide you with account login - with the one-click login function, third-party service providers may obtain your necessary device information, network- related information, geolocation, storage (photo albums, media and other documents) (including information collected in the background);

b. third-party account login function: in order to provide you with the function to login with third party account, third-party service providers may obtain your necessary device information, network- related information, geolocation, storage (photo albums, media and other documents) (including information collected in the background);

c. message push service: in order to provide you with message push, third-party push service providers may obtain your push SDK version number, necessary device information, mobile phone status information, geolocation, network - related information, storage (photo albums, media and other documents) (including information collected in the background) in order to push information that may be more interesting to you;

d. location-based service: in order to provide you with location-based service (content recommendation, content publishing, editing of the receipt information during shopping, data editing), third-party location-based service providers may collect information about your device and your Location in order to push nearby content to you;

e. cloud storage service: in order to provide you with cloud storage service (the pictures, audio and video contents you upload to Xiaohongshu will be stored in the cloud and related scenes), third-party service providers may collect information about your device, network-related information and operator information;

f. account security service: in order to protect the security of your and other users' accounts and property and prevent your and our legitimate rights and interests from unlawful infringement, third-party security service providers may collect your necessary information about your device, network-related information, operator information, log information and storage (photo albums, media and other documents) (including information collected in the background) for the purpose of providing account security service;

g. payment service: in order to ensure that you successfully purchase goods/services and virtual goods on the platform, third-party payment service providers may collect information about your device, network and operator for the purpose of smooth completion of payments and security of payments;

h. live service: in order to ensure the smooth use of the live function on the platform, third-party service providers may collect information about your device, network, push SDK version number and operator information.

(4) When you choose to participate in the marketing activities held by us, our affiliates or third parties on the platform, you may be required to provide your name, gender, mailing address, contact information and bank account information. Such information may involve sensitive personal information. Any refusal to provide such information may affect your participation in the relevant activities, but shall have no impact on other functions. We may share such information with our affiliates or third parties only with your consent, so as to ensure that you receive consistent services in the activities or entrust third parties to timely pay your rewards to you.

(5) Necessary sharing with our affiliates: We may share your personal information with our affiliates. We will only share the personal information that is necessary and such sharing shall be governed by the purposes stated in this Privacy Policy. If an affiliate wants to change the purpose of processing personal information, it will again obtain your authorization and consent;

(6) Login and use of the Xiaohongshu Video. After you authorize us to synchronize your account and relevant information with the Xiaohongshu Video, you will be able to use relevant services and functions of Xiaohongshu and the Xiaohongshu Video through the same account.

(7) You may share your personal information or other information with third parties (including unspecified persons) in the Xiaohongshu App. However, Xiaohongshu shall have nothing to do with the disclosure and use of such information as a result of your sharing, and Xiaohongshu shall not bear any legal liability.

2. Transfer:

Transfer means the transfer of control of your personal information to any other company, organization or individual. We will not transfer your personal information to any other company, organization or individual without your express consent. However, the following circumstances are excepted:

(1) Your prior consent shall have been obtained;

(2) The transfer is raised by you yourself;

(3) In the event of any merger, division, dissolution or bankruptcy of the Company, which may involve the transfer of personal information, we will inform you of the name and contact information of the recipient, and request the new company or organization that holds your personal information to continue to comply with this Privacy Policy. If the recipient changes the purpose or method of processing personal information, we will require the recipient to obtain your express consent again.

(4) Other circumstances provided by laws and regulations.

3. Public disclosure:

Public disclosure means the release of information to the public or non- specific groups. In principle, we will not publicly disclose your personal information. However, the following circumstances are excepted:

(1) To show relevant desensitized information when publicizing your account winning prize or punishment notice;

(2) Having obtained your express consent.

4. Exceptions to Authorized Consent for Sharing, Transfer and Public Disclosure of Personal Information

In accordance with relevant laws and regulations, we may share, transfer or publicly disclose your personal information without your prior authorization in the following circumstances:

(1) It is necessary for the conclusion and performance of any contract to which you are a party, or necessary for the implementation of human resources management in accordance with labor rules and regulations formulated in accordance with applicable laws or collective contracts concluded in accordance with applicable laws;

(2) It is necessary for the performance of statutory duties or obligations;

(3) It is necessary to respond to public health emergencies, or to protect the life, health and property safety of natural persons in emergency situations;

(4) It is for the purpose of public interests to carry out news reporting and supervision by public opinion; processing personal information to a reasonable extent;

(5) Processing personal information that is publicly disclosed by individuals or other lawfully public personal information to a reasonable extent in accordance with the provisions of the Personal Information Protection Law of PRC;

(6) Other circumstances provided by laws and regulations.

Please understand that pursuant to applicable laws, regulations and regulatory requirements, sharing and transferring of anonymized personal information of which the recipient cannot recover and re-identify the subject do not need to give further notice to you and obtain your consent.

IV. How We Store and Protect Your Personal Information

1. Storage:

1.1 Storage location: We will keep the personal information obtained by us from sources within PRC. In the following circumstances, we will ensure that we provide your personal information to foreign entities subject to compliance with our obligations under laws:

(1) Are expressly required by applicable laws;

(2) Have obtained your express authorization;

(3) Make cross-border transactions through the Internet or other your personal initiatives.

Our provision of Xiaohongshu Services globally means, with your prior written consent, that we may transfer or be accessible to your personal information to jurisdictions other than the country in which you use the Xiaohongshu Services. In relation to providing your personal information to third parties outside your jurisdiction, we will ensure that your personal information is protected to extent no less than required by applicable laws, including through standard contractual clauses approved by the European Commission or other competent authorities.

1.2 Storage duration: We undertake at all times to store your personal information as required by laws, for such period as is reasonably necessary to achieve the purposes stated in this Privacy Policy. We determine the storage duration of personal information based on the following criteria:

(1) To provide you with our Xiaohongshu Services and maintain relevant business records in response to any inquiry or complaint you may have;

(2) To ensure the safety and quality of the services we provide you;

(3) Whether you would agree to a longer storage duration;

(4) As required by the statute of limitations;

(5) Whether there are other special agreements or provisions of laws and regulations regarding the storage duration.

After the storage duration is exceeded, we will delete your personal information or anonymize your personal information in accordance with the applicable laws.

If we cease operation, we will promptly cease the activities of collecting your personal information in accordance with applicable law, notify you of the cease of operation by delivering the notice one by one or making a public announcement, and delete or anonymize the personal information we hold about you.

2. Protection:

In order to protect your personal information, we will endeavor to adopt various security measures in line with industry standards to protect your personal information in order to minimize the risks of destruction, theft, leakage, unauthorized access, use, disclosure and alteration of your personal information. We will actively establish data classification and grading system, data security management standard and data security development standard to manage and standardize the storage and use of personal information, to ensure that no personal information not related to the services we provide is collected.

All of your accounts are equipped with security protection functions, please keep your account and password information properly. Xiaohongshu will ensure that your information will not be lost, misused or altered by backing up other servers, encrypting user passwords and implementing relevant security measures. Notwithstanding the above security measures, please be aware that there is no “perfect security measures” on the information network. To prevent the occurrence of security incidents, we have established proper early warning mechanisms and emergency plans in accordance with the provisions of laws and regulations. If a security incident does occur, we will promptly notify you of the relevant information by mail, letter, phone call, push notice and other relevant methods. If it is difficult to notify the subjects of personal information one by one, we will adopt reasonable and effective methods to make public announcements. In the meantime, we will, in accordance with the requirements of regulatory authorities, actively report the handling of personal information security incidents, and closely cooperate with the government authorities.

When any of Xiaohongshu Services cease operation, we will immediately stop the activities of collecting personal information. We will notify you of the above changes by push notice, announcement and relevant forms, and within a reasonable period of time, we will delete your personal information or anonymize it. (“anonymization” refers to a process in which the subject of personal information cannot be identified through technical processing of personal information, and the processed information cannot be restored. The information obtained after anonymization of personal information is not personal information.)

Ⅴ. How You Manage Your Personal Information

We attach great importance to and make every effort to protect your rights to your personal information.

1. Self-determination to Receive Information

The information of the accounts you actively choose to follow will be displayed in the [following], and you can choose to follow or unfollow according to your needs.

2. Right to Access, Rectify and Delete

Through the design of the interactive interface, we provide you with methods to access, correct and delete relevant personal information. You can set it up in the following ways:

(1) Access and rectify your own personal information through [I - Edit Profile Information], including avatar, nickname, gender, permanent residence, college and enrollment date, birthday and profile;

(2) Set up, access and rectify account information through [I - Settings - Account Security], including mobile phone number (which can only be changed once a month), login password and bound third-party platform accounts (including WeChat, Weibo and QQ accounts);

(3) Set up, access and rectify privacy information through [I - Settings - Privacy Settings], including comment setting, @ setting, address book recommendation setting, Weibo recommendation setting, location information setting and blacklist setting;

(4) Access, rectify or delete relevant information through [I -Posts/Collects/Likes].

In addition to the above, we shall delete your personal information, or you shall have the right to request us to delete such information, in any of the following circumstances:

(1) The purpose of disposal has been achieved, is unable to be achieved or is no longer necessary for achieving the purpose of disposal;

(2) We have stopped providing Xiaohongshu Services, or the storage period has expired;

(3) You have expressly withdrawn your consent;

(4) If you have good reasons to believe that we process your personal information in violation of laws, administrative regulations or agreements; or

(5) Other circumstances provided by laws and administrative regulations.

3. Change or Withdrawal of Authorization

You may change or withdraw the scope of authorization through [Me-Settings - Notification Settings/Privacy Settings/General Settings], including: 1) binding to your WeChat account, Weibo account and QQ account; 2) interaction, private message, community content, and mall notification; 3) comment setting, @ setting, address book recommendation setting, Weibo recommendation setting, location information setting and black list setting; 4) setting of obtaining and using default system fonts.

You may also change or withdraw the authorization for microphone (recording), address book, notification, network, camera, calendar, floating windows, geolocation, camera, storage (album, media and other files), and phone status permissions through the operating system of the device itself. Different device models may have different functions. We will collect personal information based on the settings for which you change or withdraw the authorization. If you withdraw the authorization, we will no longer collect information related to those permissions, but you are aware that this may result in the unavailability of some or all of the functions. Furthermore, your decision to change or withdraw the authorization will not affect our previous processing of personal information based on your authorization.

4. Conditional Right to Transfer Personal Information

If you need to transfer your personal information to other platforms, companies or organizations, you may contact us through the method disclosed in this Privacy Policy. We will review your request, and will provide you with a way to transfer your personal information if it is in compliance with the provisions of the Cyberspace Administration of China.

5. Restraint of Automated Decision Making

In some business functions, we may make decisions only based on information systems, including algorithms, and non-human automatic decision making mechanisms. If these decisions significantly affect your legal rights and interests, you have the right to ask us to explain or reject our decisions made only through automatic decision making, and we will provide appropriate remedies.

6. Right to Prevent Processing for Purposes of Direct Marketing: You may contact us at any time through the contact information in Section 11 of this Privacy Policy and request us to stop using your personal information for direct marketing purposes, which refers to serving any advertisement to you in any way.

7. Right to Prevent the Data Processing likely to Cause Damage or Distress: If you find that our data processing practices may cause material harm or significant inconvenience to you or others, you may request us to cease such data processing practices by contacting us through the contact information in Section 11 of this Privacy Policy and stating the specific reasons, and request us to delete the relevant personal information in accordance with applicable laws and regulations.

8. Subject to the relevant legal requirements, your immediate relatives may exercise the above rights of access, correction and deletion of your relevant personal information, except as otherwise arranged by you.

9. Our Response to Requests

For security and identification reasons, you may not be able to access, correct or delete certain information (information after real-name authentication, part of your usage records and other relevant information) directly through the Xiaohongshu App. If it is necessary for you to access, rectify or delete such information as required by law, please email your question to the specified email address using the contact information provided in Section 11 of this Privacy Policy and we will review the question as soon as possible, and respond to you promptly after verifying your identity.

VI. How to Cancel Your Account

You may cancel your account through [Me – Settings – Help Center – Community Questions – How to Cancel Account] or [Me - Settings - Account Security – Account Cancellation], and choose [Application for Cancel Account] when you meet the conditions for account cancellation. We will process it for you as soon as possible within 7 working days after receiving your cancellation application and verifying your identity. After your account is cancelled, your personal information will be removed from the Xiaohongshu App, except for the personal information that we must retain as explicitly required by laws (for example, the information relating to your transactions in the Xiaohongshu App).

VII. Special Instruction on Products and/or Services Provided by Third Parties

Xiaohongshu App may contain products and/or services provided by third parties or provide links to information and/or services provided by third parties. You may need to redirect to the corresponding applet or third party website before using such products and/or services. Any use by you of the services of the third party (including any personal information you provide to the third party) shall be subject to the terms of service and privacy policy (other than this Privacy Policy) of the third party. You need to read them carefully and decide whether to accept them. Please take good care of your personal information and provide it to others only as necessary. This Privacy Policy only applies to the information we collect, store, use, share and disclose, and does not apply to the services provided by any third party or the rules of any third party. Any third party is solely responsible for the use of your personal information.

VIII. How We Use Cookie and Other Similar Technologies

1. When you accept cookies, Xiaohongshu will set or retrieve cookies on your computer and related mobile devices so that you can log in or use the Xiaohongshu Services or functions that rely on cookies. Xiaohongshu uses cookies to provide you with more thoughtful personalized services, including promotional services.

2. You have the right to accept or decline cookies. You can change the way your browser is set or set it on your mobile device. However, if you choose to decline cookies, you may not be able to log in or use Xiaohongshu Services or functions that rely on cookies.

3. This Privacy Policy shall apply to the relevant information obtained through the cookies set up in the Xiaohongshu.

IX. Protection of Minors' Personal Information

Minors (especially child under the age of 13) shall read the following carefully with the company of their guardians. The guardians shall decide whether to accept or decline this Privacy Policy after fully understanding it:

1. If a user is a minor under the age of 18 (especially a child user under the age of 13), he/she shall read this Privacy Policy and use relevant services of the Xiaohongshu under the guardianship and guidance of his/her guardian and with the consent of the guardian.

2. We attach great importance to the protection of minors' personal information. Minors are requested to be more aware and cautious when filling in their personal information, and to use Xiaohongshu Services correctly under the guidance of their guardians.

3. We will protect the confidentiality and security of minors' information in accordance with relevant national laws and regulations as well as this Privacy Policy. If we find that we have collected minors' personal information without the prior and verifiable consent of their parents or legal guardians, we will try to delete the relevant data as soon as possible. Meanwhile, we have established strict rules for the collection and use of minors' information to protect the personal information of children and teenagers. You may read the Xiaohongshu Personal Information Protection Rules for Children/Teenagers for more details. If you are the guardian of a minor, please contact us promptly in accordance with the contact information provided in Section 11 of this Privacy Policy if you have any concerns about the use of our services by the minors or the user information provided to us.

X. How We Update the Privacy Policy

1. In order to provide you with better services, we may update the provisions of this Privacy Policy in accordance with new products and relevant laws and regulations. Such updates will become part of this Privacy Policy. We will not reduce your rights under this Privacy Policy as currently in effect without your express consent.

2. We will notify you of any updates to this Privacy Policy via our application push notification or other reasonable means so that you are kept informed of the latest version.

XI. How to Contact Us

If you have any complaints, suggestions or questions about the protection of personal information, or if you have any questions about this Privacy Policy, you may contact us in the following ways. We will review the issues as soon as possible and respond to you within 15 working days after verifying your identity:

Email: shuduizhang@xiaohongshu.com

Company name: Xingin Information Technology (Shanghai) Co., Ltd.

Address: The registered address is Rooms C201, C202, C203, C204, C205, C206 and C207, C/F,Fuxing SOHO Plaza, No. 368, Madang Road, Huangpu District, Shanghai.

Contact Number: +86-95218999

In principle, we will respond to your request within 15 working days. If the data protection laws and regulations in your jurisdiction have special provisions, we will respond to your request within the time required by the corresponding laws and regulations.

XII. Miscellaneous

1. If there is any dispute arising out of this Privacy Policy and our processing of your personal information, you may file a complaint with Shanghai Huangpu District People's Court.

2. If you believe that our processing of personal information has harmed your legitimate rights or interests, you may also file a complaint with our primary regulatory authority, the Cyberspace Administration of Shanghai or your local regulatory authority.

3. See Attachment 1 for a special notification based on California data protection laws.