MetroMan Privacy Policy

Effective Date: July 10, 2025 Last Updated: July 10, 2025

1. Introduction

Welcome to MetroMan! Our services are jointly operated by Beijing MetroMan Technology Co., Ltd. (registered in China) and Expanse, LLC (registered in Japan) (collectively, "we," "us," or "MetroMan").

This Privacy Policy ("Policy") applies to your use of the MetroMan Website (with the primary domain https://www.metroman.cn and all its language versions, such as sub-paths /en, /ja, /zh-hant, collectively the "Website") and the MetroMan mobile applications for iOS and Android (the "App") (collectively, "our Services").

Generally, when you are located in Mainland China, your data is primarily processed by Beijing MetroMan Technology Co., Ltd. When you are located outside of Mainland China, your data is primarily processed by Expanse, LLC. Please note that certain third-party services (such as advertising SDKs) may be contracted with and processed by a specific entity according to their own policies, as detailed below.

This Policy is intended to clearly explain how we collect, use, store, share, and protect your personal information during your use of our Services, and to outline the rights you have.

Before using our Services, please read and fully understand all the terms of this Policy. By starting or continuing to use our Services, you acknowledge that you have read, understood, and agreed to all terms of this Policy.

2. How We Collect and Use Your Information

To realize the core functions of our Services and optimize your experience, we will collect and use your personal information in accordance with the principles of lawfulness, fairness, and necessity.

2.1 Information You Provide to Us

When you contact us through the "Contact Us" page or by sending an email directly to our support address, we collect your email address and any information contained in your message in order to respond to your inquiries, feedback, or technical support requests.

2.2 Information We Collect Automatically

When you use our Services, we automatically collect necessary information to ensure the proper operation, security, and functionality of the Services:

• Device and Network Information: Device model, operating system and version, browser type, IP address, network information, unique device identifiers (such as IDFA, OAID/GAID, IMEI, Android ID, MAC address), and app version.
• Log and Usage Data: Your operational logs, page clicks, access dates and times, features used, app crash logs, and performance diagnostics (such as launch time).
• Location Information (with your permission): When you use location-based features like route planning or searching for nearby stations, we will, upon receiving your explicit consent, collect your precise or approximate location information. You can disable location permissions at any time in your device's system settings.
• Cookies and Similar Technologies (Mainly for the Website): We use cookies to remember your language preferences and to speed up page loading. You can manage or delete cookies through your browser settings.

2.3 Information Collected Through Third-Party SDKs

To provide you with rich features, display advertisements to keep our Services free, and analyze service performance, our Services integrate several third-party Software Development Kits (SDKs). These SDKs may collect some of your information, and their data processing activities are governed by their respective privacy policies. We have conducted strict security assessments of the SDKs we partner with.

The following is a list of the main third-party SDKs we integrate and their data processing practices:

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

We are cautious about sharing your information and do so only when necessary and as permitted by law.

• Sharing: We do not share your personal information with any third-party companies, organizations, or individuals, except in the following cases:
  1. With Your Explicit Consent: After obtaining your separate consent, we may share your information with third parties you have agreed to.
  2. With Third-Party Service Providers: To achieve the functions described in Section 2.3 of this Policy, we must share necessary information with SDK service providers, after it has been de-identified or anonymized.
  3. For Legal Reasons: As required by laws and regulations, for litigation or arbitration purposes, or as mandated by administrative or judicial authorities.
• Transfer: We will not transfer your personal information to any company, organization, or individual, except in cases of a merger, acquisition, or bankruptcy liquidation, where we will require the new holder of your personal information to continue to be bound by this Policy.
• Public Disclosure: We will only publicly disclose your personal information with your explicit consent or as required by law.
• We solemnly promise that we will never sell any of your personal information.

4. Your Rights Regarding Your Personal Information

We fully respect your control over your personal information. You may exercise your rights in the following ways:

• Access and Correct Your Information: As we do not have an account system, most of your information cannot be accessed directly. If you believe that information we hold about you (such as your contact email) is incorrect, you may contact us to correct it.
• Delete Your Information: You may request that we delete your personal information under conditions stipulated by law.
• Change or Withdraw Your Consent:
  • Location Permissions: You can turn off location services for our App at any time in your device's operating system settings.
  • Personalized Advertising: You can limit or reset your Advertising ID (IDFA/OAID) through your device's system settings (iOS: "Settings > Privacy & Security > Tracking"; Android: "Settings > Google > Ads") to manage personalized ads.
  • For Users in the EEA/UK and other applicable regions: You can review or change your consent status for advertising data processing at any time through the consent management dialog provided by Google's UMP within the App.
• Lodge a Complaint: If you believe that our processing of your personal information has infringed upon your legal rights, you may file a complaint with us through the contact methods at the end of this Policy, or with a competent supervisory authority.

To exercise these rights, please contact us at metromanchina@gmail.com. We will respond within 15 working days after verifying your identity.

5. Data Storage and Security

• Storage Location: You understand that our Services rely heavily on third-party SDKs, and therefore your personal information is primarily collected and processed directly by the third-party service providers listed in Section 2.3. The storage location of their data is determined by their respective privacy policies. For our part, our website servers are located at the Alibaba Cloud Hangzhou node within the People's Republic of China, and the data we process and store on these servers (such as website access logs) will be retained within China. Some third-party SDKs (such as Google, Meta, etc.) may transfer the data they collect to their servers located outside of your country/region. For details, please review their respective privacy policies.
• Retention Period: We retain your personal information only for the period necessary to fulfill the purposes described in this Policy, unless a longer retention period is required by law. For example, website log data is typically retained for no more than 180 days. After the retention period expires, we will delete or anonymize your personal information.
• Security Measures: We have implemented industry-standard security measures, including HTTPS encrypted transmission, access controls, vulnerability scanning, and data backups, to protect your information from unauthorized access, disclosure, use, modification, damage, or loss.

6. Children's Privacy

Our Services are intended for a general audience and are not directed at children under the age of 14 (or the equivalent minimum age in the relevant jurisdiction). We do not knowingly collect personal information from children. If you believe we have inadvertently collected such information, please contact us so we can take steps to delete it.

7. Changes to This Policy

We may revise this Policy from time to time. When we make material changes (such as reducing your rights or expanding the scope of information processing), we will notify you through a prominent notice on our Website or within the App, and we may require your renewed consent. For non-material changes, we will post the update directly on this page.

8. Contact Us

If you have any questions, comments, or complaints regarding this Privacy Policy, please contact us:

• Email: metromanchina@gmail.com

We will respond to your request within 15 working days.

9. Governing Language

This Policy is provided in multiple languages. In the event of any discrepancy or ambiguity between the English version and any other language version, the English version shall prevail.