Mirly HarmonyOS Privacy Policy

Version 1.2.0. Effective date: 2026-10-14. Applies to the harmony / cn release.

This HarmonyOS CN shell retains the existing domestic SDK and feature baseline and does not add Google/Firebase/AdMob/UMP. App-controlled analytics and diagnostics follow the current privacy choice; withdrawal stops new app-controlled analytics and diagnostics, while SDK base instances, system diagnostics or vendor-automatic behavior may remain. We do not promise that all SDK activity stops.

Platform: HarmonyOS Developer: Beijing Chenghan Bowen Education Technology Co., Ltd. Contact: contact@chenghanbowen.com

This English version is provided for convenience. If it differs from the Chinese version, the Chinese version will prevail to the extent permitted by applicable law.

1. Scope

This Policy applies to the Mirly HarmonyOS app and related mirror preview, photo/video, media access, sharing, feedback, HarmonyOS AdsKit advertising, first-party promotion, Umeng analytics/APM, legal, and support services.

2. Information We Process

• Camera preview frames for the real-time mirror feature. By default, preview frames are processed on device and are not used for face recognition.
• Photos, videos, and video audio that you actively capture, preview, save, or share.
• Image/video files you select or generate. Media location information is accessed only where authorized and needed by media-related system capabilities.
• Accelerometer permission for mirror preview, orientation sensing, display effects, or related interactions.
• Feedback text, contact details, selected screenshots or attachments, product line, platform, package, version, channel, installation ID, device manufacturer, model, and system version.
• Advertising and promotion data after consent, including HarmonyOS AdsKit requests, OAID where authorized, ad impressions, clicks, redirects, frequency control, and anti-fraud signals.
• Sharing and backup data when you actively use system sharing or enable system backup/cloud backup.
• Legal page parameters used to display legal pages.

3. Permissions

Mirly HarmonyOS may request camera, microphone, media location, accelerometer, network, network-state, app-tracking/OAID consent, system photo picker, media saving, system sharing, and system backup capabilities. Each permission or system capability is used only for the related feature.

4. Third-Party Services

The app may use HarmonyOS AdsKit/OAID, Umeng HarmonyOS analytics/APM, WeChat Open SDK if you actively use WeChat-related features and the client calls it, a QQ/system sharing adapter that currently does not depend on QQ Open SDK, first-party promotion services, and HarmonyOS system media/sharing/backup services.

5. Your Rights

You can manage permissions in HarmonyOS Settings and contact contact@chenghanbowen.com to access, correct, delete, or withdraw consent for personal information where supported by law and product capability.

Children's Personal Information Protection Rules

This is a standalone children's personal information section within this Privacy Policy. “Child” means a minor under 14. Mirly is a general mirror tool and is not specifically directed to children.

When the app is first opened or asks for privacy consent again, if the user may be under 14, a guardian should read this section and this Policy first and decide whether to consent. Before guardian consent, you may continue to use Basic Services that do not depend on that consent. Processing that needs separate consent or an active request occurs only when its stated conditions are met. We do not ask children to provide a birthday, age, identity document, or similar information for routine use.

Current processing facts for this platform:

• Local content: Mirror preview, photo/video capture, video audio, media saving/reading, media location when authorized and required by the system, accelerometer, system sharing, and backup continue under the existing HarmonyOS features; preview frames are processed locally in real time and are not used for face recognition. The three platforms currently provide no account registration or sign-in.
• Active feedback, installation, device, and SDK data: When you actively submit feedback, feedback content, contact details, selected screenshots or attachments, product line, platform, package, version, channel, installation ID, device maker/model, and OS version are used for issue handling. HarmonyOS AdsKit/OAID, Umeng OAID/AAID, device/network, page/tap/performance information, and first-party promotion installation, slot, and interaction events are described in the relevant sections of this Policy.

The retention period, storage location, sharing scope, and handling by third-party services for children's information are described in the corresponding storage, sharing, and third-party service sections of this Policy. When a guardian makes a request, we handle it under this Policy and applicable law; previously submitted feedback or saved data is not automatically deleted.

A guardian may contact contact@chenghanbowen.com to request access to, correction or deletion of children's personal information, or withdrawal of the related consent. To prevent impersonation, we perform only necessary and proportionate verification for an application. If we discover that children's personal information was processed without guardian consent, we will stop the related processing and delete or anonymize it as required by applicable law.

Privacy Choices and Withdrawal

Use the app's Privacy Choices/Privacy Management entry in Settings to review the current state or choose again. If you previously consented, confirm “Withdraw Privacy Consent” before switching to Basic Services; canceling that confirmation leaves the existing choice unchanged. Resuming the relevant optional features requires your explicit consent and does not replay prior ad requests or impressions. Withdrawal cancels current ad preparation and pending presentation, stops new advertising requests, and disables optional analytics and diagnostics controlled by the app. Basic features that do not depend on that consent remain available. SDK base instances, system diagnostics, or vendor-automatic behavior may still exist or run; this does not mean all SDKs automatically stop and does not guarantee zero SDK activity before consent. Withdrawal does not affect processing already lawfully completed or automatically delete submitted feedback or previously saved data. Deletion requests use the existing contact and handling procedures. The app's main privacy choice is separate from system permissions and personalized-ad settings. This shell does not add the Global Android/iOS Google/Firebase/AdMob/UMP route.