Last updated: October 1, 2026
Effective date: October 1, 2026
Welcome to the services of the Mindway Platform!
This Policy applies to the Mindway website (mindway.chat), the Mindway Pro mobile apps (Android, iOS, HarmonyOS) and the desktop clients (Windows, macOS, Linux; collectively, the "Product"). Key updates in this revision: supplemental provisions for the desktop clients (Chapter IX), real-name verification of mobile phone numbers, log retention periods, content security review and handling of violations, mobile app permissions and third-party SDKs, descriptions of generative AI services (including data involved in voice input and online retrieval), in-app purchases (subscriptions), and in-app complaints/reports and account deletion.
MindwayPlatformis provided by Siyuan Xingzhi (Beijing) Technology Co., Ltd. (registered address: Room A5526, 4/F, Building 1, Yard 2, Yongcheng North Road, Haidian District, Beijing; hereinafter "we", "us" or "our")via the Internet asintelligent learning and academic creationtechnology services(hereinafter the "Service"). We fully understand the importance of Personal Information to you, and your trust is of great importance to us. We will strictly comply with the requirements of laws and regulations and adopt corresponding security protection measures to safeguard the security of your Personal Information. Accordingly, we have formulated this "MindwayPlatform Privacy Policy" (this "Policy") to help you fully understand how we collect, use, share, store and protect your Personal Information in the course of your use of the Service, and how you can manage your Personal Information, so that you can make appropriate choices.
Before you formally start using the Service, please be sure to read and understand this Policy carefully first, paying particular attention to the clauses we have marked in bold, and make sure you fully understand and agree to them before you begin. In addition to this Policy, in specific scenarios we may also explain to you the corresponding purposes, scope and methods of information collection through just-in-time notices (including pop-ups, on-page prompts, etc.), feature update notes and other means. Such just-in-time notices and feature update notes form part of this Policy and have the same effect as this Policy.
For the technical terms used in this Policy, we explain them to you in plain and simple language as much as possible to facilitate your understanding. If you have any questions, comments or suggestions about the content of this Policy, you may contact us using the contact details at the end of this Policy.
This Policy will help you understand the following:
I. Scope of This Policy
II. How We Collect and Use Your Personal Information
III. How We Share, Transfer and Publicly Disclose Your Personal Information
IV. How We Protect and Retain Your Personal Information
V. How You Manage Your Personal Information
VI. Special Provisions on the Information of Minor Users
VII. Updates to This Policy
VIII. How to Contact Us
IX. Supplemental Provisions for the Desktop Clients (Mindway Pro)
I. Scope of This Policy
1.1 This Policy applies to the various products and services we provide to you. If a product or service provided by us or our affiliates has its own separate privacy policy or similar legal document, that separate document shall prevail.
1.2 This Policy does not apply to services provided to you by other third parties. The processing and protection of your information shall be governed by the privacy policies or similar documents of such third parties, and we assume no legal liability for any third party's improper use or disclosure of the information you provide.
II. How We Collect and Use Your Personal Information
We will collect and use your Personal Information for the following purposes described in this Policy.We understand that the conversation information you enter, the feedback you submit and other information you provide to us (including images, videos, etc.) may contain the personal information of others. In such cases, please be sure to obtain their lawful authorization before providing it, so as to avoid improper disclosure of others' personal information.
2.1 Registration/Login
2.1.1 We provide services to you based on yourMindwayPlatform account.To create a Platform account, you need to provide us with the following necessary information: your mobile phone number or email address. You may also log in with a third-party account such as Google, Apple or GitHub, in which case we will obtain the unique identifier of that third-party account and the email address you authorize it to provide. If you refuse to provide the above necessary information, you will not be able to create a Platform account or use our products directly or by calling API interfaces, and may only use the browsing services. In addition, you may choose whether to provide your company name, job title, email, telephone number, country/region and city, specific use cases, usage experience and referrer. We further clarify that
the mobile phone number you submit will also be used to receive verification codes when you log in, bind your account or retrieve your password, and will serve as one of the designated contact methods between you and us for receiving relevant service notices (such as new product launches, service changes, etc.).
2.1.2 You may log in to your account by verifying a verification code using your mobile phone number or email address, or by using your account password or one of the third-party accounts mentioned above. To safeguard account security, we apply rate limiting to login and verification code requests, and consecutive incorrect attempts will temporarily lock login.
2.2Real-Name Verification
Pursuant to the requirements of laws and regulations such as the Cybersecurity Law of the People's Republic of China on the verification of users' real identity information, you must bind a mainland China mobile phone number and pass SMS verification code verification before you can use services such as dialogue and content generation. Users who register with an email address or a third-party account will be guided to complete mobile phone number binding after logging in; each mobile phone number may be bound to only one account.
SMS verification codes are sent by the SMS service provider (Alibaba Cloud). Your mobile phone number is used only for identity verification, login and account security; it will not be displayed publicly and will not be used for any other purpose without your explicit authorization. If you do not complete mobile phone number binding, you will not be able to use services such as dialogue and content generation, but you may still log out or delete your account.
2.3 Human-Computer Interactive Dialogue and Content Generation
After you have created a Platform account, you can interact with ourMindwayPlatform by clicking buttons or through the dialogue box, or generate content. We will automatically receive and record the text, images or videos that you voluntarily enter while interacting with theMindwayPlatform, and use such information to output content to you, so as to provide human-computer interactive dialogue and content generation services. While using the Service, you may also evaluate the content output by theMindwayPlatform. We will collect your evaluation information, including the error reasons you actively submit, so as to continuously improve the output content quality of theMindwayPlatform.
Online document editing:When you open or edit a Word (.docx), PowerPoint (.pptx), Excel (.xlsx) or PDF document in Mindway, the document file is uploaded to our online document service (office.mindway.chat) to enable online viewing and editing. The uploaded document is used only to provide you with viewing and editing and any AI reading and modification you actively initiate; when you save your edits, the result is written back to your device, and once you close the document, its copy on the server is deleted. Before you open such a document for the first time in the mobile app, we will separately prompt you and obtain your consent; if you do not agree, you will not be able to open such documents online, but this will not affect your use of other features.
If you refuse to let us collect and process the foregoing Personal Information, please exercise caution when entering such information; however, this may affect your normal use ofMindwaysome or all of the features provided by the Platform.
2.4Usage History
To provide you with a continuous and consistent usage experience and to ensure service quality, we will record your personal usage records, including the information you enter and the content generated based on such information. You can find and manage your usage history that you have not deleted. Please be aware that, to comply with relevant laws and regulations and to fulfill network information security obligations, we will retain your usage history and generated content for the period permitted by law.
2.5 Providing You with Stable Services
To ensure the normal operation of the Service, we may collect log data generated during your use of the Service (including your browser information and type, the date and time of your requests, and how you interact with our website), usage information (your location, such as client date and access time, server date and access time, type of computer or mobile device, and network information), device information (including information about the device you are using, operating system and browser type), Cookies, etc., to help us analyze service performance and further help us effectively enhance your usage experience. In particular, we promise not to use Cookies for any purpose other than those described in this Policy. We use Cookies mainly to keep the service experience secure and running efficiently; they enable us to confirm the security status of your account, troubleshoot anomalies related to crashes and latency, and save you the steps of repeatedly filling in forms and entering search content.
2.6 Providing You with Security Protection
To improve the security of the Service, protect the personal safety, property safety and account security of you, other users or the public, better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions and malicious programs, and more accurately identify violations of laws, regulations or relevant agreements and rules, we and our affiliates will collect your device information and log information, and may use or integrate your device information and log information to comprehensively assess your account and usage risks, perform identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis and handling measures in accordance with the law.
To fulfill our statutory cybersecurity obligations, we will record operation logs of your registration, login, mobile phone number binding, dialogue and content generation requests, reports, account deletion and other operations, including the account, mobile phone number, operation type, time, IP address and port, and device and client information, and will retain them for no less than six months in accordance with the law. The above logs are used only for ensuring security, handling complaints, and cooperating with relevant authorities in accordance with the law.
2.7 Customer Service Function
On the premise that the information has been de-identified and can no longer be re-linked to a specific individual, we may collect your evaluations and feedback to improve the dialogue quality of the Mindway platform and optimize the service experience. If you refuse to provide us with the foregoing information, you may not be able to enjoy certain additional services we provide to you, but you can still use the basic functions of the Service normally.
2.8 Other Purposes
We will not use the content you enter or the content generated based on it to train models. On the premise of not disclosing your Personal Information and not violating relevant laws and regulations, we may analyze de-identified usage statistics (such as feature usage frequency and error rates) to improve service quality.
2.8.2 When we display your Personal Information, we will display it in de-identified form by such necessary means as content replacement, anonymization and de-identification, so as to protect the security of your information.
2.8.3 When we intend to use your Personal Information for other purposes not stated in these personal information protection rules, or to use information collected for a specific purpose for other purposes, we will seek your consent in advance.Please understand that the services we provide to you will be continuously updated and changed. If you choose to use other features not yet listed in these personal information protection rules, before we collect your Personal Information, we will explain to you in detail, by reasonable means, the purpose, method and scope of the information collection and seek your explicit consent. If you do not agree to provide the foregoing information, you may not be able to use the relevant services.
2.9 Exceptions to Prior Authorization and Consent
Please note: in the following circumstances, the collection and use of Personal Information does not require your prior authorization and consent:
2.9.1 Directly related to national security or national defense security;
2.9.2 Directly related to public security, public health, or major public interests;
2.9.3 Directly related to criminal investigation, prosecution, trial and enforcement of judgments;
2.9.4 Necessary for the performance of statutory duties or statutory obligations;
2.9.5 Necessary to protect the life, property and other major lawful rights and interests of you or other individuals, where it is difficult to obtain the consent of the person concerned;
2.9.6 The Personal Information collected has been made public to the general public by you on your own;
2.9.7 The Personal Information is collected from lawfully and publicly disclosed information, such as legitimate news reports, government information disclosure and other channels;
2.9.8 Personal Information is processed within a reasonable scope for news reporting, public opinion supervision and other acts carried out in the public interest;
2.9.9 Necessary for the conclusion or performance of a contract to which you are a party, or necessary to provide services to you at your request;
2.9.10 Necessary for maintaining the secure and stable operation of the services provided, such as discovering and handling service failures;
2.9.11 Other circumstances provided for by laws and regulations.
2.10 Mobile App Permissions
The Mindway Pro mobile app requests the following system permissions only when you actively use the corresponding features. You may turn them off at any time in your system settings; turning them off does not affect the use of other features:
(1) Camera: used to take photos that are sent to the AI as images for recognition;
(2) Microphone: used for voice input; voice is used only for real-time transcription into text;
(3) Storage / Photos and Videos: used to select images to upload and to save generated images and videos.
We will not request permissions unrelated to the Service, such as location, contacts, call logs, SMS, or reading phone status. When you launch the app for the first time, we will show you the key points of this Policy in a pop-up; before you tap "Agree", the app will not collect your Personal Information.
2.11 Generative AI Services
(1) The text you enter and the images and documents you upload are sent via our servers to large model services that have completed algorithm filing (mainly Qwen (Tongyi Qianwen), DeepSeek, Tongyi Wanxiang and others provided on the Alibaba Cloud Bailian platform; algorithm filing number: 网信算备330110507206401230035号) to generate responses. The Mindway Pro mobile app only calls large model services that have been filed within mainland China. When you use voice input, the recording is sent via our servers to the speech recognition model on the Alibaba Cloud Bailian platform and is used only for transcription into text. When you use web search or literature retrieval, your search keywords are sent via our servers to retrieval services such as Web of Science, Semantic Scholar, OpenAlex, arXiv and Tavily in order to return retrieval results; we only send the keywords needed for the retrieval.
(2) AI-generated text is labeled "AI-Generated" in the interface, and generated images and videos are labeled "AI-Generated/Synthetic", with the implicit identifiers embedded by the model service provider retained. AI-generated content may contain errors; please review it carefully.
(3) We do not collect biometric information such as facial features or voiceprints, and we do not provide face-swapping or voice-cloning features.
2.12 Content Security and Handling of Violations
To prevent illegal and harmful information, we perform automated security checks on your input content and on AI-generated content. Requests that fail the checks will be rejected or generation will be stopped, and the check results (account, time, IP address, matched category and content excerpt) will be recorded. For accounts that repeatedly enter illegal or non-compliant content, we will take measures such as usage restrictions or bans in accordance with the User Agreement; if you disagree with any such action, you may appeal through the channels described in Chapter VIII of this Policy. The relevant records are retained for no less than six months in accordance with the law.
2.13 Subscriptions and In-App Purchases
When you purchase a subscription in the iOS version of Mindway Pro, payment is completed by Apple. We do not obtain your payment information such as bank card details; we only receive the transaction receipt returned by Apple (transaction number, subscribed product, subscription period and expiration time), which is used to activate, renew and manage your membership benefits and to handle refunds and reconciliation. Subscriptions you purchase on other platforms (the official website, Android, HarmonyOS, etc.) are processed by the corresponding payment channels, and membership benefits under the same account can be used across platforms. You can manage or cancel your subscription in the "Subscriptions" settings of your Apple ID.
III. How We Share, Transfer and Publicly Disclose Your Personal Information
Certain modules and features of our products and/or services will be provided by service providers. To this end, we may share some of your Personal Information with partners in order to provide better customer service and user experience. When cooperating with such partners, we will adhere to the following principles: (1)the principle of lawfulness, legitimacy and minimum necessity: data processing shall have a lawful basis and a legitimate purpose, and shall be limited to the minimum scope necessary to achieve the purpose of processing; (2)the principle of maximizing the user's right to know and right to decide: the user's right to know and right to decide regarding the processing of their Personal Information shall be fully respected in the course of data processing; (3)the principle of maximizing security protection capability: we will take necessary measures to safeguard the security of the Personal Information processed, prudently assess the purposes for which partners use the data, comprehensively evaluate the security protection capabilities of these partners, and require them to comply with the relevant requirements of the cooperation agreements.
3.1 Entrusted Processing
We may entrust authorized partners (such as technical service providers, authorized partners, etc.) to process your Personal Information so that they can provide certain services or perform certain functions on our behalf. We will only entrust them to process your information for the lawful, legitimate, necessary, specific and explicit purposes stated in this Policy. Authorized partners may only access the information needed to perform their duties, and we will require them by agreement not to use such information for any other purpose beyond the scope of the entrustment. If an authorized partner uses your information for a purpose we have not entrusted, it will separately obtain your consent.
The authorized partners we entrust include:
Third-party service providers: to provide you with the real-name verification service described in Section 2.2 of this Privacy Policy, we may entrust third-party service providers to process your Personal Information, including your mobile phone number and the verification codes you receive. We will require third-party service providers to use your Personal Information only for the purpose of completing real-name verification or for other purposes prescribed by laws and regulations, and not to use your Personal Information for any reason other than such purposes.
Affiliates: we may provide necessary Personal Information to our affiliates to implement certain features of the Service for you, subject to the purposes stated in this Privacy Policy. If an affiliate changes the purpose of use and processing of the Personal Information you provide, it will seek your authorization and consent again.
3.2 Sharing with Third Parties
In principle, we will not share your user information with other organizations or individuals, except in the following cases:
3.2.1
Sharing with your explicit consent: after obtaining your explicit consent, we will share your user information with other parties. 3.2.2
Sharing necessary for the performance of statutory obligations: we may share your user information externally as provided by laws and regulations, for the needs of litigation or arbitration resolution, or as required by administrative or judicial authorities in accordance with the law.
3.2.3
Sharing necessary for the conclusion or performance of a contract to which you are a party。
3.3 Transfer
In principle, we will not share your user information with other organizations or individuals. However, in the event of a merger, acquisition or bankruptcy liquidation between us and other legal entities, or other circumstances involving merger, acquisition or bankruptcy liquidation, if a transfer of user information is involved, we will require the new company or organization holding your user information to continue to be bound by this Policy; otherwise, we will require such company, organization or individual to seek your authorization and consent again. If bankruptcy is involved and there is no successor, we will delete the data in accordance with the law.
3.4 Public Disclosure
We will only publicly disclose your user information in the following circumstances:
3.4.1 With your full consent or based on your voluntary choice, we may publicly disclose your user information; or
3.4.2 To protect the personal and property safety of the Platform, the users of its affiliates or the public from harm, we may disclose your user information in accordance with applicable laws or the Platform's relevant agreements and rules. For example, if you, as a cloud marketplace service provider, sell counterfeit or pirated goods, we may publicly disclose the entity information of your store and the penalties imposed.
3.5 Exceptions to Prior Authorization and Consent When Providing User Information Externally
In the following circumstances, user information may be provided externally without your prior authorization and consent:
3.5.1 Related to national security or national defense security;
3.5.2 Related to public security, public health, or major public interests;
3.5.3 Related to criminal investigation, prosecution, trial and enforcement of judgments;
3.5.4 Necessary to protect the life, property and other major lawful rights and interests of you or other individuals, where it is difficult to obtain the consent of the person concerned;
3.5.5 Personal Information that you have made public to the general public on your own;
3.5.6 Personal Information collected from lawfully and publicly disclosed information, such as legitimate news reports, government information disclosure and other channels;
3.5.7 Necessary for the performance of our statutory duties or statutory obligations, or for responding to instructions from government authorities.
3.6 Third-Party SDKs and Services
To implement the features of the Product, we have integrated the following third-party SDKs or services, which process necessary information in accordance with their own privacy policies:
(1) DCloud uni-app x engine (Digital Heaven (Beijing) Network Technology Co., Ltd.): the Mindway Pro mobile app is developed based on this engine. To troubleshoot engine failures, the engine collects device information (device brand and model, CPU type, screen parameters, operating system name and version, network type, IP address, User Agent, device language, time zone, whether it is an emulator or rooted, and anonymous device identifier) and application information (app name, package name, version, error stack traces), which are collected by the SDK itself. Privacy policy: https://dcloud.io/license/appprivacy.html
(2) Alibaba Cloud SMS service (Alibaba Cloud Computing Co., Ltd.): sends SMS verification codes for login, mobile phone number binding and account deletion, and processes your mobile phone number and verification codes.
(3) Alibaba Cloud Bailian large model service (Alibaba Cloud Computing Co., Ltd.): provides model capabilities for dialogue and content generation, and processes the text you enter, the images and documents you upload, and recordings made during voice input.
(4) Google, Apple and GitHub account login: used only when you choose to log in with the corresponding method; processes the third-party account identifier and the email address you authorize.
(5) Bing, Tavily and academic retrieval services (Web of Science, Semantic Scholar, OpenAlex, arXiv and Tavily, etc.): process your search keywords only when you use web search or literature retrieval.
(6) Apple App Store in-app purchase: when you purchase a subscription in the iOS version, payment is completed by Apple. We do not access your payment information such as bank card details and only receive the transaction receipt returned by Apple, which is used to activate and renew your membership.
IV. How We Protect and Retain Your Personal Information
4.1 We attach great importance to the security of your information. We endeavor to adopt various reasonable physical, electronic and managerial security measures to protect your user information and to prevent user information from unauthorized access, public disclosure, use, modification, damage or loss. For example, we use encryption technology to improve the security of user information; we use trusted protection mechanisms to prevent user information from malicious attacks; we deploy access control mechanisms to endeavor to ensure that only authorized personnel can access user information; and we hold security and privacy protection training courses to strengthen employees' awareness of the importance of protecting user information.
4.2 We will take reasonable and feasible measures to endeavor to avoid collecting irrelevant user information. We will only retain your user information for the period necessary to achieve the purposes described in this Policy, unless otherwise permitted by law. Among such information, operation logs, content security check records and complaint and report records are retained for no less than six months in accordance with the law. After the above retention period for user information expires, we will delete or anonymize your Personal Information.
4.3 Although we have taken reasonable and effective security measures in accordance with the requirements of relevant laws and regulations, we cannot guarantee one hundred percent information security due to technical limitations and possible malicious means. Please know and understand that the systems and communication networks we provide may experience problems due to factors beyond our control. Therefore, we strongly recommend that you take active measures to protect the security of your Personal Information, such as using complex passwords, changing passwords regularly, and not disclosing your account password and related Personal Information to others.
4.4 In the unfortunate event of a user information security incident (leakage, loss, etc.), we will promptly inform you in accordance with the requirements of laws and regulations of: the basic circumstances and possible impact of the security incident, the measures we have taken or will take, suggestions on how you can guard against and mitigate risks on your own, and the remedial measures available to you. We will promptly notify you of the relevant circumstances of the incident by email, letter, telephone, push notification or other means; where it is difficult to notify each user information subject individually, we will publish an announcement in a reasonable and effective manner. At the same time, we will also report the handling of the user information security incident to the regulatory authorities as required.
4.5 In the event that our products and services cease operation, we will take reasonable measures to protect the security of your user information, including promptly stopping the continued collection of user information; notifying users of the cessation of operation by individual delivery or announcement; and deleting or anonymizing the Personal Information we hold.
4.6 In principle, Personal Information generated or collected in the course of our business operations within the People's Republic of China will be stored within the People's Republic of China; unless it is necessary to provide you with a particular service, we will only transfer your Personal Information outside the territory after obtaining your separate consent and taking other measures required by laws and regulations. The Mindway Pro mobile app only uses large model services filed within mainland China and will not transfer your Personal Information overseas as a result. Some retrieval services used for web search and literature retrieval (such as Bing, Tavily, arXiv, etc.) are located outside mainland China and process your search keywords only when you actively use these features; if you do not want your search keywords to be sent overseas, please do not use the web search and literature retrieval features.
V. How You Manage Your Personal Information
5.1 Access, Correction and Supplementation
If you need to access, correct or supplement your Personal Information as described below, please submit a request by contacting [support@mindway.chat]:
5.1.1 If you need to access your recent conversation history information, or to correct or supplement conversation topic names;
5.1.2 If you wish to access, correct or supplement your account information, or to query or manage (change, delete) the basic business information (basic profile) and contact information submitted when using the Service.
5.2 Copying
If you need to make a copy of your Personal Information as described below, please submit a request by contacting support@mindway.chat:
5.2.1 If you need to copy your recent conversation history information;
5.2.2 If you need to query or manage (change, delete) the basic business information (basic profile) and contact information submitted when creating and using the account service.
5.3 Deletion
If you need to delete your Personal Information as described below, please submit a request by contacting [support@mindway.chat]:
5.3.1 If you need to delete your recent conversation history information;
5.3.2 If you need to delete the basic business information (basic profile) and contact information submitted when using the Service.
5.3.3 In the following circumstances, you may contact us and submit a request to delete other information:
(1) If our processing of user information violates laws or regulations;
(2) If we collect or use your user information without obtaining your explicit consent;
(3) If our processing of Personal Information seriously violates our agreement with you.
5.3.4
After you, or we with your assistance, delete the relevant information, we may not be able to immediately delete the corresponding information from our backup systems due to applicable laws and security technology limitations. We will securely store your Personal Information and restrict any further processing of it until the backups can be cleared or anonymization can be achieved.
5.4 Changing or Withdrawing the Scope of Authorization
5.4.1 You may contact us viasupport@mindway.chatto change or withdraw the scope of your authorization for us to collect and process your Personal Information.
You may also turn off permissions such as camera, microphone and storage in your system settings to withdraw authorization for the corresponding features.
5.4.2
After you withdraw your consent, we will no longer process the corresponding Personal Information. However, your decision to withdraw consent will not affect the Personal Information processing activities we previously carried out based on your authorization.
5.5 Account Deletion
You may also delete your account yourself in the Mindway Pro mobile app or desktop client via "Account Menu — Delete Account" (if this entry is not yet available in the desktop client, please apply via the email address above). After deletion, we will immediately revoke all of your login credentials, delete your conversations, Cloud Notes, tasks, Knowledge Base, files and other data, and unbind third-party accounts; operation logs and financial records that must be retained by law will be deleted or anonymized after being retained for the statutory period.
5.5.2
After you voluntarily delete your account, we will stop providing products or services to you and will delete your Personal Information or anonymize it, unless otherwise provided by laws, regulations or industry regulatory rules.
5.6 Responding to Your Above Requests
5.6.1 For security purposes, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.
5.6.2 For your reasonable requests, we do not charge fees in principle, but for requests that are repeated multiple times and exceed reasonable limits, we reserve the right to charge a certain fee at our discretion. We may refuse requests for information not directly associated with your identity, requests for information repeatedly applied for without reasonable justification, or requests that require excessive technical means (such as developing new systems or fundamentally changing existing practices), pose risks to the lawful rights and interests of others, or are impractical.
5.7 Subject to compliance with relevant legal requirements, your close relatives may, after we verify their identity, exercise the above rights of access, correction, deletion, copying, etc. with respect to your relevant Personal Information, unless you have made other arrangements.
5.8 Exceptions to Responding to Your Rights Requests
In the following circumstances, we have the right not to respond to your above rights requests:
5.8.1 Related to our performance of obligations prescribed by laws and regulations;
5.8.2 Directly related to national security or national defense security;
5.8.3 Directly related to public security, public health, or major public interests;
5.8.4 Directly related to criminal investigation, prosecution, trial and enforcement of judgments;
5.8.5 We have sufficient evidence that you or other Personal Information subjects are acting with subjective malice or abusing rights;
5.8.6 Necessary to protect the life, property and other major lawful rights and interests of you or other Personal Information subjects, where it is difficult to obtain the authorization and consent of the person concerned;
5.8.7 Responding to your or other Personal Information subjects' requests would cause serious harm to the lawful rights and interests of you or other Personal Information subjects or organizations;
5.8.8 Involving trade secrets.
VI. Special Provisions on the Information of Minor Users
6.1 We provide the Service and other related products primarily to adults. However, we attach great importance to the protection of minors' Personal Information. If you are a minor, we require you to ask your parents or other guardians to carefully read all of the content of this Policy, and to use our products or services and provide information to us only with the consent of your parents or other guardians.
6.2 Due to existing technology and business models, it is difficult for us to proactively identify the Personal Information of minors during account registration. If you are the guardian of a minor and discover that we have obtained a minor's Personal Information without authorization, you may contact us through the contact details published in this Policy. Upon receiving your notice, we will promptly verify the matter and, if verified, promptly delete or anonymize the relevant information. If we proactively discover the foregoing circumstances through review, we will also proactively delete or anonymize the relevant Personal Information.
VII. Updates to This Policy
7.1 To bring you a better service experience, we continuously endeavor to improve our technology. We may update this Privacy Policy and remind you of the updated content by SMS or other appropriate means so that you can stay informed of the latest version of this Privacy Policy. However, without your explicit consent, we will not restrict the rights you enjoy under this Policy.
7.2 For material changes, we will also provide more prominent notice (including notification by SMS or email, or providing you with a pop-up prompt) to inform you again, and will obtain your consent in accordance with the relevant requirements of laws and regulations.
VIII. How to Contact Us
If you have any questions or comments about the content of this Policy, or about any of the practices and operations described above, you may contact us by sending an email tosupport@mindway.chat. We will respond to your request within 15 days. If you are not satisfied with our resolution, you have the right to file a complaint with the China Internet Reporting Center.
Operator: Siyuan Xingzhi (Beijing) Technology Co., Ltd.; Registered address: Room A5526, 4/F, Building 1, Yard 2, Yongcheng North Road, Haidian District, Beijing; Contact of the Personal Information Protection Officer: support@mindway.chat.
Complaints and reports: if you find illegal or non-compliant content, harmful information or content that infringes your rights, you may report it through the following channels, and we will handle it and respond within 15 working days: (1) "Account Menu — Complaints and Reports" in the Mindway Pro mobile app; (2) the "Report" button below each AI response; (3) sending an email to support@mindway.chat. You may also report to the Reporting Center for Illegal and Harmful Information of the Cyberspace Administration of China (https://www.12377.cn, tel. 12377).
IX. Supplemental Provisions for the Desktop Clients (Mindway Pro)
This chapter supplements the foregoing provisions and applies only to the Mindway Pro desktop clients (Windows, macOS, Linux). For the desktop clients, in case of any inconsistency with the foregoing provisions, this chapter shall prevail.
9.1 First Launch and Consent
On first launch, the client will show you a Personal Information protection guide. Before you tap "Agree", the client will not automatically check for updates and will not send any of your content to any AI service; you may also choose "Quit App". Account login requires you to actively check and agree to the "User Agreement" and the "Privacy Policy".
9.2 Content Sent to Third-Party AI Services
The text, images, document content and voice that you enter or select in features such as AI dialogue, writing, literature retrieval, image and video creation, voice input and Cloud Notes retrieval are sent through the Mindway platform to third-party service providers that provide model and retrieval capabilities (such as Alibaba Cloud Bailian and other model and retrieval service providers) for processing, in order to generate the results you request. Some models are provided by overseas service providers; when you choose such models, the relevant content will be transmitted to the location where their services are based for processing. Please do not enter sensitive information that you do not wish to be processed. We only share such content to the extent necessary to provide the services you request.
9.3 Microphone
The client uses the microphone only after you tap the voice input button, and the audio collected is used for speech recognition and transcription into text. The client does not record audio when you have not started voice input. You may turn off the microphone permission at any time in your operating system's privacy settings; this will only make voice input unavailable and will not affect other features.
9.4 Local Files and Local Data
The documents you open, workspace folders, conversation records and settings are primarily stored locally on your device. Only when you use features such as Cloud Notes, AI dialogue attachments, Knowledge Base and online document editing will the relevant content be uploaded to our services. The client's runtime logs and crash dumps are stored locally on your device and are not automatically uploaded.
9.5 Other Network Requests Initiated by the Client
(1) Update checks: the client obtained from the official website requests a version manifest from Mindway's update service; the request includes the client version and operating system type. Versions obtained through app stores such as the Mac App Store or Microsoft Store are updated by the store, and the client does not initiate such requests. (2) Device interconnection: after login, the client registers this device's device identifier, device name and online status with the Mindway service for multi-device collaboration. (3) Online document editing: when Word, Excel, PPT or PDF files are edited online, the opened file is uploaded to Mindway's document service (office.mindway.chat) for editing and saving, unless you have deployed the document service on your own machine. (4) PlantUML diagrams: when a document contains PlantUML diagrams, the diagram source code is sent to www.plantuml.com for rendering. (5) Third-party login: when you choose to log in with a third-party account such as WeChat, Google, Apple or GitHub, authorization is completed on the corresponding service provider's page, and we only receive the authorization result. (6) Online support: the client generates a QR code locally; after scanning it, you will enter Tencent Enterprise WeChat (WeCom) customer service, which is provided by Tencent.
9.6 AI-Generated Content Labeling
The client labels AI responses with "AI-Generated", labels image and video results with "AI-Generated/Synthetic", and displays in the input area the notice "Content is generated by AI; please review it carefully." AI-generated content may be inaccurate; please verify it yourself before use.
9.7 Reporting and Account Deletion
You may report illegal, non-compliant or infringing content to us via "Complaints and Reports" in the client's user menu or the report button below each AI response; you may also send an email to support@mindway.chat. We will respond with the handling result within 15 working days. You may also report to the Reporting Center for Illegal and Harmful Information of the Cyberspace Administration of China (12377). For account deletion, please see Section 5.5 of this Policy.
9.8 App Store Versions
When you obtain the client through an app store, the store operator may collect download and usage statistics in accordance with its own policies, for which it is independently responsible; in-app purchases (if any) are handled in accordance with the store's rules.
Appendix: Relevant Definitions
Personal Information: all kinds of information recorded electronically or by other means that relate to an identified or identifiable natural person, excluding anonymized information.
Sensitive Personal Information: Sensitive Personal Information is Personal Information that, once leaked or illegally used, may easily lead to infringement of the dignity of a natural person or harm to personal or property safety, including biometric information, religious beliefs, specific identity, medical and health information, financial accounts, whereabouts and tracks, as well as the Personal Information of minors under the age of fourteen.
Children: refers to minors under the age of fourteen.
Device Information: includes hardware model, hardware serial number, software list, list of installed applications, list of installed software, unique device identifier IMEI, device MAC address, SIM card IMSI information, Android ID, MEID, OpenUDID, GUID, Bluetooth information, broadcast component communication information, ICCID, BSSID, SSID, carrier information, sensors (gyroscope, gravity sensor, accelerometer, ambient sensor, optical heart rate sensor) and clipboard. The actual collection shall prevail.
Log Information: includes time, user ID, conversation ID, conversation content, as well as IP address, browser type, telecom carrier, language used, and access date and time.
De-identification: refers to the process by which Personal Information is processed so that it cannot identify a specific natural person without the aid of additional information.
Anonymization: refers to the process by which Personal Information is processed so that it cannot identify a specific natural person and cannot be restored.
Cookie: Cookies and similar device identification technologies are technologies commonly used on the Internet. When you use the Service, we may use such technologies to send one or more Cookies or anonymous identifiers to your device to collect, identify and store information about your access to and use of the Product.
