Privacy Policy

Last Updated on August 1st 2023

The products/service are provided by TENORSHARE（HONGKONG）LIMITED (hereinafter referred to as "Tenorshare", "we" or "The Company", whose registered address is at ROOM C22 10/F NO.52 HUNG TO ROAD KWUN TONG KL, personal information security officer can be reached at [email protected]). We attach great importance to protecting the privacy of our users (or "you"), and we are committed to respecting and protecting the personal information we collect. The data controller is TENORSHARE（HONGKONG）LIMITED and its affiliated companies(including but not limited to HITPAW CO., LIMITED, AFIRSTSOFT CO.,LTD)

Tenorshare has appointed an EU representative in accordance with the Regulation No. 2016/679 on the protection of natural persons with regard to the processing of Personal Data (the "GDPR"). You can contact the designated EU representative of Tenorshare by reaching [email protected].

This Privacy Policy explains how we collect, use, store, share and otherwise process your personal information when you use our websites/products/service. This Privacy Policy will help you understand the followings:

Ⅰ. How we collect and handle your information, and what information we collect from you

Ⅱ. How we store, protect and transfer your information

Ⅲ. How we use Cookie and similar technologies

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

Ⅴ. How you shall manage your personal information

Ⅵ. How we handle the personal information of minors

Ⅶ. Permissions of users in different regions for their personal information

Ⅷ. How the Policy will be updated

Ⅸ. How to contact us

Ⅰ. How we collect and handle your information, and what information we collect from you

1. The personal information we may need to collect and use about you regarding your use of our websites/products/service includes the following two circumstances:

a. In order to provide you with the basic features of our websites/products/service, we may need your permission to collect and use the necessary information. In the event that you refuse to provide the corresponding information, you will not be able to have proper access to or use our websites/products/service.

b. In order to provide you with additional features of our websites/products/service, you may have the option of accepting or refusing to provide us with certain information about yourself, and the type and scope of personal information collected for the basic features and additional features may differ. If you refuse to provide us with such information, you will not be able to use the additional features or reach the desired results, but this will not prevent you from using the basic features.

2. The specific scenarios in which we collect and use your information for functional purposes:

a. Visiting or using our websites

When users visit our website, your browser will send certain information to our server. This information is automatically recorded by our server and belongs to the Internet product log information. Generally this log information contains the following content:

  • Date and time of the visit and the duration of use of the Site;
  • Information about how you visit our Sites (including the webpage that led you to our Site, the search terms entered into a search engine which led you to our Sites);
  • Your operations and clicks to our Sites;
  • Date and time of the visit and the duration of use of the Sites;
  • Information about your device (type of device, clicks on Web requests from browser, browser type and version, as well as settings, installed plug-ins, operating system, IP address). Such information is in most cases collected in an anonymous manner.

b. Using our products/service

When you are using our products/service, we may ask for various permissions and collect different data depending on the product. Generally, if you use our websites/products/service, depending on the features, we may ask for your permission to get access to PC system administrator, reading/writing local files, reading/writing registry, reading/writing local storage, and other accesses. For products related to users' phones such as phone data repair and phone password management, it is also necessary to connect to the users' phones and obtain permission to read phone data.The personal information we collect through the aforementioned permissions is limited to the following: We collect information about the products which you use and how you use them, including but not limited to Product serial number, Launch data, Feature usage, Page clicks, Sign-in information; Your local device information, including but not limited to your device information, device hardware, operating system, software version, Mac address, IP address, operating log information, the size and format of the files you are working with (but not the original file documentation); Desktop product operation logs, operation crash reports, etc.

Please note that when you switch the software to run in the background, due to certain device models and system reasons, the information collection behavior resulting from your previous use of the product-related features may not cease immediately. There could be a brief period during which background information collection continues.

c. Creating your account

You can create an account while visiting or using our websites/products/service to better enjoy the entire experience of them. When creating a new account, you may need to provide all or some of the following information: your username, E-mail address, phone number, social media accounts, country/region etc. Such information is used for account creation and user self-display, and will help you retrieve your account more easily if you encounter account problems such as loss of your account.

d. Logging in with or sharing to third party services

Signing up or logging in with a third party account(such as Google, Facebook, Apple ID etc.) or share with the aforementioned third parties. For the purposes mentioned above, you acknowledge and consent that we may acquire and collect information about you from these third parties or provide your information, such as your personal profile (ID, avatar, etc.) that is publicly available to third parties, and other information that you have agreed to authorize at the authorization page.

e. Transaction and payment

When you make a purchase and payment transaction for our product, we collect the billing information that you submit by yourselves: name and email address, country/region, zip code, first six and last four digits of your credit card account, credit card expiration date, billing address, type of product you purchase, amount you pay in your currency, subscription ID, subscription-related URLs (such as purchase confirmation page URL, subscription cancellation URL, invoice PDF URL).

We will use the transaction and payment information to process billing, renewals, and any subsequent refund services related to your order. The relevant information will also be used for internal financial record-keeping purposes.

We do not collect or process the data about your payment instruments such as credit card numbers, banking account numbers or Pay Pal accounts. This information is collected, processed and stored by our qualified payment processors.

f. Customer service and dispute handling

When you contact us or submit a request for resolution of an ongoing sale, after-sales, or dispute, we may require you to provide the necessary personal information to verify your identity in order to ensure the security of both your account and our system. In order to easily reach you, help you with the problems in a timely manner, or to keep records of the solutions and results of such problems. We may archive your records of your communications, correspondence/calls and related content (including account information, address, email address, other contact information and other information you provide to prove the relevant facts) with us. We may also use other information about you to provide customer service and to improve the quality of said service, including information you provide when you contact customer service and information you send to us in response to a survey.

g. Crash data collecting

When a user's operation crashes while visiting or using our websites/products/services, we will ask the user individually if he/she would like to send us the original reports in order to identify the cause of the bug so that we can fix the problem. We will not collect original reports from users until they have given us their consent.

h. Other contents

You may provide feedback or reviews about our products on the software store's comment section or other public platforms. We will use the comment data to improve our products. We may use the comments (with your relevant information) you post for marketing purpose to provide the consumers and potential consumers with our product information, and for others to better understand and use our products.

During your usage of our websites/products/service, we may show you ads for Tenorshare products and services that we think may interest you. If you want to cancel the aforementioned purpose, you can contact us through customer service or online forms on our websites.

From time to time, we may contact our customers directly by mail, email, or telephone to inform you about upgrades, new products, promotions, or special offers that you told us you were interested in receiving. If you want to cancel the aforementioned purpose, you can contact us through customer service or online forms on our websites.

We process Website Usage Data to allow you to surf the Sites and to ensure its functionality. We also process Website Usage Data to perform analyses on the performance of the Sites, to continuously improve the Sites and correct errors, to ensure IT security and operation of our systems, as well as to prevent or uncover abuse. We further process this data in aggregated or pseudonymized form to analyze trends, administer the Sites, track users' movements around the Sites, and to gather demographic information about our user base as a whole or to improve marketing (including serving you personalized, interest-based ads) as well as the user experience on our Site and guaranteeing the safety of our IT systems.

We process Product Usage Data and Product Installation Data so that we can facilitate, evaluate, and verify your use of our products and services. We will also use the Product Usage Data for our own internal statistical and analytical purposes, and to evaluate and enhance users' experience of the Products by identifying customer preferences and analyzing crash data. If you want to cancel the aforementioned purpose, you can contact us through customer service or online forms on our websites.

During your usage of our websites/products/service, you may provide us with your information through data collection forms or other means. We will use the provided information in accordance with the agreed-upon terms, following legal and regulatory requirements. We will not use the information for any other purpose.

Ⅱ. How we store, protect and transfer your information

We will determine different retention periods according to the type of information, the purpose for which we use the information, and the period required to fulfill the purposes described in the Policy, unless a longer keeping time is required or permitted by applicable law.

We take reasonable measures to help protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration or destruction. And please help us keep your account and personal information safe by using sophisticated passwords. Please be aware that the systems and communication networks you use to access our products/services may be subject to security issues in other steps beyond our control. Please understand that in the Internet industry, due to the limitations and rapid development of technology and the possible existence of malicious attacks, even if we do our best to strengthen security measures, it is not always possible to guarantee 100% security of information.

Given the global reach of our business and to provide you with continuous services on a global scale, we may transfer the data we collect about you to secure servers or data centers located outside the country/region where the data was initially collected (including the United States, European Economic Area (EEA), or Japan) for storage and/or processing. When we transfer your data to countries/regions outside the country where the data was initially collected, we will protect the data in accordance with the explanations provided in this privacy policy and comply with applicable legal requirements to ensure adequate data protection.

Ⅲ. How we use Cookie and similar technologies

To keep our websites and products working properly, and to help make your visit experience easier and to recommend information that may be of interest to you, we may store small data files called Cookie on your computer or mobile device. Cookie allows the websites to store your preferences and other data to help you save yourself the hassle of filling in personal information and entering your search history repeatedly. And we may also use such technology to recommend, display and push contents of interest to you. We will not use Cookie for any purposes other than those described in this Privacy Policy. You can manage or delete Cookies to your preference. Most browsers have features to block Cookies and you can clear all Cookies saved on your computer with the browser's settings, but please note that if you disable all cookies, some parts of our websites may not work properly. For more information on how to change your browser settings, please visit the relevant settings page of the browser you are using.

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

In order to ensure the implementation of our product-related features and the safe and stable performance of our apps, and because some features of our products cannot be executed by us alone, we may share or entrust some of your personal information with third parties such as our partners in order to ensure the smooth implementation of our product features. You agree that we may share your personal information with affiliates that support our features, and with third parties that we integrate or access, for the purpose of providing the services to you. The support provided by these third parties includes providing us with data analysis, data storage, payment processing, image processing support. Our affiliates of our features are not authorized to use your personal information for purposes other than those set forth in this Privacy Policy and the purposes set forth herein. They shall obtain your authorized consent separately if they wish to change the purposes for which personal information is processed.

You agree that, in the event of merging, separating, acquiring or liquidating, your personal information may be transferred as part of such transaction. And we will ensure the confidentiality of such information at the time of transfer, and ensure that you will be informed of the name and contact information of the recipient. And we will require the new recipient of your personal information to remain subject to this personal information protection policy, or we will require the recipient to ask for your authorized consent again. If we rely on your consent to process your Personal Data, you have the right to withdraw your consent at any time.

We may disclose all of your information for subsequent reasons: in response to a subpoena, court order, legal process, law enforcement request, legal claim, or government investigation, to protect and defend the rights, interests, and safety of the platform, our affiliates, users, or the public.

V. How you shall manage your personal information

You have the right to access, correct, and delete the information we collect about you.If you are unable to do so, or have any questions about Personal Information we have collected and/or shared about you, or would like to withdraw your consent for our processing (i.e. entirely delete your account) please contact us at: [email protected].

We will act on the User’s requests and provide information free of charge, except where the requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case we may charge a reasonable fee (taking into account the administrative costs of providing the information or communication, or taking the action requested), or refuse to act on the request.

Ⅵ. How we handle the personal information of minors

If you are a minor, you shall use our services with obtaining prior consent of your parent or legal guardian (collectively, "guardian"). We recommend that the guardians of minors shall read this Policy carefully, and we also recommend minors to obtain guardians’ prior consent and guidance before submitting personal information in your use of our services. If you are the legal guardian of a minor, please ensure that the minor in your custody is using our products or services with your authorized consent. If you have questions about the personal information of a minor in your custody, please contact us through the means set forth in this Privacy Policy.

We are not directed to children under the age of 13 and we do not knowingly collect Personal Information from children under the age of 13. If we learn that we have collected Personal Information of a child under the age 13, we will take reasonable steps to delete such information from our files as soon as is practicable, unless we have a legal obligation to retain it. Please contact us if you believe we have any information from or about a child under the age of 13: [email protected].

Ⅶ.Permissions of users in different regions for their personal information

The GDPR, Law Concerning Protection of Personal Data of Japan and other applicable data protection laws provide certain rights for data subjects. Broadly speaking you have, or may have, the right (as more fully provided in applicable data protection laws): 

  • The right to be informed: The User has the right to be provided with clear, transparent and easily understandable information about how Tenorshare collects and uses personal data and its rights. This is the reason why Tenorshare is providing the User with the information in this privacy policy.
  • The right of access: The User has the right to obtain access to its Personal Data (if Tenorshare is processing it), and other certain information (similar to that provided in this privacy policy).
  • The right to rectification: The User is entitled to have its personal data corrected if it's inaccurate or incomplete.
  • The right to erasure: This 'the right to be forgotten' enables the User to request the deletion or removal of its personal data where there's no compelling reason for Tenorshare to keep using it.
  • The right to withdraw consent: The User has the right to withdraw a previously provided consent to processing of your personal information.
  • The right to object to processing: The User has the right to object, on grounds relating to its particular situation, at any time, to the processing of its personal data.
  • The right to restrict processing: Under certain circumstances, the User has the rights to 'block' or suppress further use of its personal data.
  • The right to data portability: to receive its Personal Data provided to Tenorshare in a structured, commonly used and machine readable format and has the right to transmit those data to another controller.
  • The right to lodge a complaint: to complain about our processing of your personal information to a local supervisory authority.

It is important to be aware that these rights may not be absolute. For example, if you withdraw your consent to our processing of your personal information, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

In the event of a data leak, we will inform the regulatory authorities and users of the leaked information in a timely manner. If you have any questions about the matters covered by this policy, please contact our Data Protection Officer at [email protected].

Exercise the above rights, you can send an email to customer service email: [email protected], or fill out our request form here.

Rights regarding personal information for California residents

Pursuant to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), California residents receive certain rights with respect to their personal information, as described below. These rights are not absolute and are subject to certain exceptions more fully set forth in the CCPA. California residents have the right not to receive discriminatory treatment from us for the exercise of the privacy rights conferred by the CCPA.

California residents have the right to obtain access to its Personal Data (if Tenorshare is processing it), and other certain information (similar to that provided in this privacy policy).

California residents have the right request that businesses stop selling or sharing your personal information ("opt-out"), including via a user-enabled global privacy control. Businesses cannot sell or share your personal information after they receive your opt-out request unless you later authorize them to do so again..

California residents have the right to know about personal information collected, disclosed, or sold. Each California resident has the right to request, subject to certain exceptions described in the CCPA, that we disclose to that resident: 

  • the categories of personal information we have collected about them,
  • the categories of sources from which the personal information is collected,
  • the business or commercial purpose for collecting or selling the personal information,
  • the categories of third parties with whom we have shared the personal information,
  • the specific pieces of personal information we have collected about them (collectively, a "Request to Know"),
  • the business or commercial purpose for collecting or selling the personal information,

California residents have the right to restrict our use Sensitive Personal Information collected about you.

In the past 12 months we have collected, and in the future we will continue to collect, the categories of personal information cited in the section entitled “The personal information we collect” above. This includes the following categories of personal information set out in the CCPA: identifiers, personal information described in Section 1798.80 of the California Civil Code, characteristics of protected classifications under California or federal law, Internet or other electronic network activity information, geolocation data, professional or employment-related information and sensitive personal information. We collect and use this information and from the sources described in the section entitled “How we collect and handle your information, and what information we collect from you” above, and share this information with third parties as described in the section entitled “How we share, transfer and disclose your personal information” above.

We do not sell your personal information as defined under the CCPA or share your personal information for cross-contextual behavioral advertising purposes and we do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. We do not use or disclose sensitive personal information for purposes other than those permitted purposes specifically identified in the CCPA and its implementing regulations.

Right to request deletion of personal information

Each California resident has the right to request the deletion of their personal information that we collect or maintain (a "Request to Delete"), subject to certain exceptions set forth in the CCPA.

Each California resident has the right to request the correction of any inaccurate personal information that we maintain (a "Request to Correct"), subject to certain exceptions set forth in the CCPA.

To make the aforementioned Request, you can send an email to customer service email: [email protected], or fill out our request form here.

Process for verifying requests of California residents

In order to protect your privacy and security, prior to completing any Request to Know, Request to Delete or Request to Correct that you may submit, we must verify your identity. We will verify your identity by asking you to provide certain data that we have already collected from you to confirm that they match our records. In certain instances, additional verification steps may be required.

Authorized agents

California residents have the right to designate an authorized agent to make a request under the CCPA on their behalf. Prior to completing a request made by such an authorized agent, we require that you provide your authorized agent with written permission to submit such a request and require that you or your authorized agent provide us with a copy of such written permission. Additionally, we require that you verify your identity pursuant to the procedure described above.

Keeping personal information

Your personal information will be retained in accordance with our Data Privacy Policy.

We retain personal information of different types, or relating to different categories of people, for different periods, taking into account its business purpose. For example, information about individuals who have applied for employment with us will be retained for a shorter period than information about individuals who have actually worked for us.

The periods for which we retain information are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used. We take into account legal and regulatory provisions which require information to be retained for a minimum period. We also consider the limitation periods for taking legal action and good practice in the legal industry.

If you have any questions on the matters covered in this policy, you can send an email to customer service email: [email protected].

Changes to our privacy policy

We regularly review this Privacy Policy and may make changes as our services or privacy practices change, or as required by applicable laws or regulations. Future versions of our Privacy Policy will be available on our website. We encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

Ⅷ. How the Policy will be updated

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of the new Privacy Policy, posting the new Privacy Policy, or providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you visit the Platform to stay informed of our privacy practices.If you do not agree to the effective changes, you shall stop accessing or using our websites/products/service on the effective date determined by the changes, and the changes shall have no effect on you. If you continue to access or use our websites/products/service after the effective date of the changes, you shall be deemed to have agreed to the effective changes.

Ⅸ. How to contact us

If you have any questions, inquiries, opinions, suggestions or complaints regarding the Policy or personal information protection, you can contact us through our online customer support.

In addition, you may also reach us by means of: