Petal Interconnect Privacy Policy

Updated: November 23, 2025

Dear User,

Thunder Software Technology Co., Ltd. (hereinafter "ThunderSoft" or "we") highly respects your privacy and will do its utmost to protect your personal information. This Petal Interconnect Privacy Policy ("this Policy") applies to the collection, processing, storage, transfer, and protection of user information during the use of the Petal Interconnect application (together with all related content, "this Service"). Please read this Policy before using this Service and make sure you have understood and agreed to it, paying special attention to the important content in bold. You must undertake that when you start using this product you are already an adult. If you are a minor, you need the consent of your guardian to use this product and accept this Privacy Policy and the relevant terms of service. If you use this Service, it means that you have read, acknowledged, and accepted the provisions of this Privacy Policy. Based on the necessity and efficiency of providing the Service, we will strictly comply with the requirements of this Privacy Policy and use and protect your information.

1. Transfer of User Content

(1) You acknowledge that this Service is used to transfer contacts, images, music, videos, and other content supported by this Service (collectively "User Content") from one device to another authorised device.

(2) When you transfer a type of User Content for the first time (for example, when you transfer photos from your device for the first time), we will ask for your prior authorisation to access that content.

(3) Some User Content will be displayed on the interface of this Service in the form of images, summaries, or other tangible forms. The specific display will be randomly generated and updated based on the User Content stored on your device.

(4) User Content may only be transferred to the specific device authorised to receive the content in a single transfer. With respect to any User Content, we only provide a service that helps transfer from one device to another; we do not collect it from you, nor do we obtain, process, or use it in any way.

2. Information We Collect

(a) Your device information: When you use this Service on a particular device, we collect specific information from that device, including device identifier, device model, device name, system version, and network information (local IP address, gateway IP address) to identify the version, quickly diagnose errors, troubleshoot issues, ensure functional compatibility, improve the product in a timely manner, and provide version update notifications.

(b) Your log information: During your use of this Service, we will collect service logs (including usage duration, amount of transferred data, data type, operation status, connection status, and other behavioral log information). The log information collected from you will be used solely to provide the basic service, analyze problems and errors that may arise during service use, and will not be linked to your personal identity.

(c) Location information: When devices connect, your location information is needed to establish the connection and discover devices, in order to complete the service function you require. Location information is only cached locally, not uploaded to servers, and not used for any unauthorized purposes.

(d) User transferred data: When you use the file transfer and other related functions, we need to cache the images, videos, texts, contacts you have selected, as well as the permission status of the application or service module you are transferring, to help you complete the transfer of such data content. The relevant data is used solely to complete the transfer; we do not perform content recognition, intent analysis, or use it for any other purpose.

3. Mutual File Transfer

(1) When you use the mutual file transfer function, we need to collect your device identifier (UUID), device model, and Bluetooth address to distinguish you from your other device and to establish pairing.

(2) Through this function, you can establish a connection with another device to receive contacts, files, images, videos, and other supported content from that device. To achieve this purpose, we need to read the user content you have selected. Such content will be automatically collected and processed by us after your consent when you use the mutual file transfer function.

4. Permission Requirements

To implement the functions of this Service, some device permissions need to be activated. The specific permissions and their authorisation purposes are as follows:

(1) Real‑time activity permission: used to show transfer progress via Dynamic Island when the application is in the background.

(2) Location permission: used to determine whether you are on the same local network.

(3) Local network and wireless data permission: used to connect devices and transfer files on the same local network.

(4) Bluetooth permission: used to search for nearby devices via Bluetooth.

(5) Contacts permission: used to read or write contact information.

(6) Photos permission: used to read or write image and video information.

(7) Camera permission: used to take photos with the camera to send feedback.

(8) Document storage permission: requires enabling permissions such as photos, camera, and contacts to read or write images, videos, and file information used by the application.

The above permissions will only be invoked when the corresponding function of this Service is being performed. Please rest assured that when you are not using the functions of this Service, it will not arbitrarily call your permissions.

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

(1) Sharing: Sharing means that ThunderSoft provides personal information to another personal information processor, and both parties independently determine the purpose and method of processing in the personal information processing activity. Generally, ThunderSoft does not share your personal information with external parties, except in the following cases:

    1. Sharing with consent: after obtaining your consent, ThunderSoft will share with the third party you designate the information within the scope of your authorisation;

    2. Sharing in legal cases: ThunderSoft may share your personal information in accordance with legal provisions, the need for dispute resolution, or the legal requirements of administrative or judicial authorities;

    3. Sharing with ThunderSoft's affiliates: your information may be shared among ThunderSoft's affiliates. We will only share your information among ThunderSoft's affiliates for specific, explicit, and legitimate purposes, and only the information necessary to provide the Service. For example, when registering a ThunderSoft account, to avoid duplicate registration, we need to check the global uniqueness of the account to be registered;

    4. Sharing with business partners: ThunderSoft may share your order information, account information, device information, and location information with third parties such as business partners, to ensure the successful completion of the service provided to you. However, we will only share your personal information for legitimate, fair, necessary, specific, and explicit purposes, and only the personal information necessary to provide the Service. Our business partners include:

        1) Third‑party sellers and third‑party developers: some products or services are directly provided to you by third parties. ThunderSoft must share the relevant transaction information with the third party to fulfill your request to purchase goods or services from them. For example, when you purchase a product from another developer in the app store, we need to share with the developer the necessary information about you for the transaction to be completed.

        2) Suppliers of goods or technology services. ThunderSoft may share your personal information with third parties that support our functions, including third parties that supply goods or provide infrastructure technology services, logistics delivery services, payment services, data processing services, etc. The purpose of sharing this information is to realize the functions of products and services. For example, we must share your order information with the logistics service provider to arrange delivery; or we must share your order number and order amount with a third‑party payment institution to enable it to confirm your payment order and complete the payment.

ThunderSoft will conduct security assessments of the sharing activity and the recipient of personal information, and will sign a data protection agreement or strict confidentiality agreement with the recipient, requiring them to process personal information in accordance with this Statement and to take relevant confidentiality and security measures.

(2) Transfer: In the event of merger, division, liquidation, acquisition, or bankruptcy, if it involves the transfer of personal information, we will inform you in advance of the name and contact information of the recipient, and require the recipient to continue to process your personal information in accordance with this Statement. If the recipient changes the original purpose or method of processing, it must obtain your consent again.

(3) Public disclosure: ThunderSoft will publicly disclose your personal information only in the following circumstances:

    1. after obtaining your consent;

    2. disclosure based on legal or reasonable grounds: if required by law, legal proceedings, litigation, or public and governmental authorities, ThunderSoft may disclose your information.

6. Cross‑Border Transfer

ThunderSoft is a multinational company, which means that your personal information collected by ThunderSoft may be processed in the country/region where you use the products or services, in other countries/regions where ThunderSoft or its affiliates, subsidiaries, service providers, or business partners have offices, or may be accessed from such countries/regions. The data protection laws of these countries/regions may differ. In such cases, ThunderSoft will take measures to ensure that the data we collect is processed in accordance with this Statement and applicable law.

Personal information collected and processed during our operations in the People's Republic of China will be stored within the territory of the People's Republic of China. If a particular product/service involves cross‑border transfer of personal information, we will provide personal information to overseas recipients only after fulfilling legal obligations (e.g., passing the security assessment of the regulatory authority).

7. Storage and Protection of Personal Information

(1) Storage period and processing after expiry: unless otherwise provided by laws and regulations, we will retain your personal information for the minimum period necessary to achieve the purposes set out in this Policy. When your personal information exceeds the storage period we have set, we will delete or anonymise it.

(2) Information security and protective measures: We will take measures including but not limited to security checks, use of encryption tools and software, and other reasonable security measures and procedures to protect your information, and will do our best to safeguard its security. When we cease operation of this Service or you stop using it, we will no longer collect or use any of your information, and will anonymise or delete the stored information.

8. Management of Personal Information

(1) You may change the scope of your authorisation for us to continue collecting your personal information or revoke your authorisation by turning off relevant functions on your device or by contacting us. Please understand that some business functions require certain basic personal information to be completed, and when you withdraw your consent or authorisation, we can no longer provide you with the service corresponding to the withdrawal, nor will we process your corresponding personal information. However, your decision to withdraw consent or authorisation does not affect the personal information processing activities carried out previously based on your authorisation.

9. Disclaimer

Although this Privacy Policy describes the standards that ThunderSoft follows in maintaining your privacy data, ThunderSoft will strictly abide by these standards and take all reasonable and feasible measures to protect your personal information and data. However, please be aware and understand that ThunderSoft cannot control all factors or how third parties collect and use your information and data, and no measure can be completely infallible. We cannot guarantee that your data and information will not be leaked under any circumstances. This Privacy Policy only applies to ThunderSoft's rules for collection, use, and sharing of information, and does not apply to any services provided by third parties or third parties' rules for collection, use, and sharing of information.

10. About this Policy

ThunderSoft reserves the right to update or modify this Policy from time to time. Once the provisions of the Privacy Policy are modified, ThunderSoft will display the update on the relevant page; if the modification materially affects your rights, it will notify you in a prominent way or re‑obtain your authorisation. Your use of this Service and continued use thereof signifies your acceptance of this Policy and its updates. If you do not agree to this Policy, please do not use this Service or disable it on your device. You can find the latest version of this Policy in the settings page.

11. Contact Us

We have established a dedicated personal information protection department and a personal information protection officer. If you have any questions, comments, or suggestions, please contact us via online customer service, or send them to our global offices. You may also contact us via our customer service hotline (62662686).

Generally, we will provide a preliminary response within three business days and answer your questions within the time prescribed by law. If you are not satisfied with our response, especially when our processing of personal information harms your legitimate rights and interests, you may also file a complaint or report with the local privacy protection regulatory authority.

12. Miscellaneous

For specific Privacy Policy matters not listed in this Agreement (including but not limited to "processing of minors' data", "how to share, transfer, and publicly disclose your personal information", "security and measures of information and data", "management of personal information", "integrity of information and data", etc.), please refer to and rely on ThunderSoft's Privacy Policy.

Important Note: Due to differences in local laws and languages, the local language version of the "Statement on Petal Interconnect and Privacy" may differ from this version. In the event of any inconsistency, the local language version shall prevail.