Introduction

This Privacy Policy describes how Hangzhou Jingzang Network Technology Co., Ltd.,  杭州景藏网络科技有限公司, or Scenic, herein referred to as: ("Company", "we", "our" or "us") collects, uses, shares, and stores personal information of users located in the People’s Republic of China ("China") through the Scenic mobile application (the "App", “Platform”), websites, software and related services accessed via any platform or device that link to this Privacy Policy. Our services are provided and controlled by Hangzhou Jingzang Network Technology Co., Ltd. We are committed to protecting your personal information and complying with the relevant laws, regulations, and technical specifications. This policy outlines how Scenic collects, uses, stores, and protects the personal data of users aged 18 and over in connection with our platform. It covers the types of data we collect, the purposes of collection, the sharing of and to third-party services, user rights (including consent, access, correction, and deletion), and our data protection practices under applicable jurisdictions.

This policy applies to the products and services provided by Scenic, but does not apply to information/services (including any third-party applications, websites, etc.) contained in or linked to by Scenic’s products or services. Such information/services are operated by the third party’s personal information protection policy or similar regulations.

Contents

How We Collect and Use Your Personal Information

Collecting Your Information

When using our products or services, you may need to authorise us to collect and use your personal information in the following situations:

Registering and logging into your account.
- Before using Scenic's products/services, you must first register an account to become a Scenic member. During registration, you must provide either a mobile phone number or email and set a password to create a Scenic account. You can also opt to provide both as a way to help with account recovery incase you forget your password. If you opt not to provide either sign up methods, you may not be able to create an account or use Scenic's products/services.
- You understand and agree that all actions you take on Scenic after logging in with your Scenic account represent your own actions. All electronic records generated from your Scenic account operations are valid evidence of your actions, and you bear full responsibility for any consequences arising therefrom.
- We may collect the following categories of personal information:
-- Account and Profile Information: name, age, username, password, language, phone number, email address, account information, and profile image, etc.
-- Verification Information: full name, ID & ID type, ID number

Providing you with products or services.
Such as creating routes, posting echoes and posts, participating in team navigation, chatting, or accessing personalised recommendations.
Sharing content, including routes, posts, media, and team events.
Controlling the visibility of your content, including: Public (visible to all users), Team Shared (accessible only to participants of a specific team route), and Private (visible only to you).
Additionally, certain metadata (such as timestamps, geolocation, or contribution points) may be associated with your content and displayed to others based on your visibility settings. We encourage users to use visibility settings cautiously and remind users to avoid posting sensitive personal information in public areas.
- Based on the above usage scenarios, we may collect the following categories of personal information:
-- Messages: information you provide when you compose, send, or receive messages through the platform’s messaging functionalities. They include messages you send through our chat functionality when communicating within team chats. That information includes the content of the messages and information about the message, such as when it was sent, received, or read, and message participants. Please be aware that messages you choose to send to other users of the platform will be accessible by those users and that we are not responsible for the manner in which those users use or share the messages.
-- Clipboard Information: texts, images, and videos, found in your device’s clipboard, with your permission. For example, if you choose to initiate information sharing with a third-party platform, or choose to paste content from the clipboard onto the platform, we access this information stored in your clipboard in order to fulfil your request.
-- User-generated Content: photos, videos, reviews, comments, text, hashtags, and the associated metadata, such as when, where, and by whom the content was created.
-- Usage Data: app interaction history, preference settings, friends, paused passengers or followers and other connections, along with information you share through surveys or your participation in research, promotions, marketing campaigns, events, or contests such as your gender, age, likeness, and preferences.

Automatically collected information.
- Such as:
-- Detailed Location, Travel, and Route Data: Location and route information is collected, for example, in the form of GPS signals (combined with a time stamp), IP address and other information from sensors and receivers on or around your device, on which the App is installed and/or activated. This location and route information is saved to a route history of all the trips you have made while using the App. The types of location data we collect depend in part on your device settings and/or your account settings. For example, depending on your selected device settings and/or your account settings, we may collect information about your location and travel (or lack thereof), also while you are not using the App, in order to be able to send you route recommendations, or let you know when planned trips are nearing their start dates and time.
-- Device Information: IP address, device type, operating system, app version, mobile carriers, time zone settings, network type, device IDs, screen resolution, app and file names and types, battery state, audio settings and connected audio devices. We automatically assign you a device ID and user ID. When you log in from multiple devices, we will be able to use information such as your device ID and user ID to identify your activity across devices. We may also associate you with information collected from devices other than those you use to log in to the Platform.
-- Usage data: We collect information regarding your use of the Platform and any other User Content that you generate through or upload to our Platform.
-- Image and Audio: We may collect information about the images, videos, and audio that are a part of your User Content, such as identifying the objects and scenery that appear, the existence and location within an image of face and body features and attributes, the nature of the audio, and the text of the words spoken in your User Content. We may collect this information for content moderation, for demographic classification, for content recommendations, and for other non-personally-identifying operations.
-- Metadata: When you upload or create User Content, you automatically upload certain metadata that is connected to the User Content. Metadata describes other data and provides information about your User Content that will not always be evident to the viewer. For example, in connection with your User Content, the metadata can describe how, when, and where, and by whom the piece of User Content was created, collected, or modified and how that content was formatted. Metadata is also used to successfully complete “Waymarks” and “Route Adventures” when taking routes that have such content.

Behavioural Analytics and User Footprint Data.
- Purpose of Collection:
To improve user experience, enhance route and content recommendations, and understand how Scenic is used, we collect limited behavioural data relating to how users interact with our app interface and content.
This includes tracking how long users view content, which filters or map features they use, and how they engage with routes or stories.
We use this information to:
-- Measure and improve the performance of Scenic’s features;
-- Suggest content that aligns more closely with user interests and preferences;
-- Identify usability issues and optimise design;
-- Ensure fair visibility of content within the community.
We do not use behavioural data for advertising purposes or share it with third parties without explicit consent.
- Categories of Data Collected:
Depending on your app activity, Scenic may collect the following non-personal interaction data:
-- Page and session duration;
-- Time spent viewing individual content items;
-- Scroll depth and interaction patterns;
-- Map interactions such as zoom, drag, and view changes;
-- Filter selections and route discovery actions;
-- Engagement signals (likes, comments, saves, shares, and follows).
These data points are pseudonymised and cannot, by themselves, identify an individual user.
- Collection and Processing Method:
Behavioural data are recorded through a secure in-app telemetry system.
Data are processed as follows:
-- Information is temporarily stored locally on your device and transmitted only after you have granted tracking consent.
-- When transmitted, data are encrypted in transit (TLS 1.3) and anonymised before storage.
-- Processing takes place within Scenic’s analytics infrastructure, hosted in Mainland China, and results are used to refine recommendations on the “Home” and “Discover” feeds.
- Legal Basis for Processing:
We process behavioural analytics data only with your consent, as required under the Personal Information Protection Law (PIPL) of the People’s Republic of China.
You may withdraw your consent at any time by navigating to:
Me > Settings > Content & Activity > Analytics.
- Retention Period:
Behavioural analytics data are retained for no longer than 180 days from the date of collection, after which they are either anonymised or permanently deleted.
Aggregated, non-identifiable metrics may be stored for longer to support long-term trend analysis and system performance monitoring.
- Data Security and Storage:
All tracking data are transmitted over secure, encrypted channels and stored in encrypted databases.
Access is limited to authorised Scenic personnel within data engineering and analytics departments.
An automated audit trail logs all access to behavioural datasets.
- Your Rights:
Under the PIPL, you have the right to:
-- Access and review behavioural data associated with your account;
-- Request correction or deletion of inaccurate or non-essential tracking data;
-- Withdraw consent for analytics collection at any time;
-- Request anonymisation of previously collected data.
To exercise any of these rights, contact privacy@scenicnav.com.
- Opt-Out and Consent Management:
You may disable behavioural analytics at any time without affecting access to Scenic’s core functions.
If you opt out, Scenic will stop collecting session duration, scroll, and map interaction data, though minimal functional data (e.g., crash logs) may still be processed for operational safety.
Consent banners and pop-ups are displayed during onboarding and before any behavioural data are collected, ensuring users make an informed choice.

Aggregated & De-Identified Information.
- Scenic may use aggregated, anonymised data to improve and scale our services. This includes:
-- Understanding how users interact with scenic routes.
-- Identifying popular regions, features, or pain points in the user journey.
-- Optimising our recommendation systems.
-- Supporting research into sustainable travel, outdoor behaviour, and route accessibility.
- This data does not include personally identifiable information and cannot be used to trace activity back to an individual user.
- Scenic may also share aggregated insights with business partners, tourism boards, and community organisations. For example, to support safe trail management or promote eco-friendly travel initiatives.
- Aggregated or de-identified data is not subject to this Privacy Policy.

Using Your Information

As explained below, we use your information to improve, support and administer the Platform, to allow you to use its functionalities, and to fulfil and enforce our Terms of Use. We may also use your information to, among other things, show you suggestions and promote the Platform.

We use your information to:
- Provide, personalise, and improve the App and services. For example: Use your location and route information and/or search query history to provide navigation services, best route recommendations, route alerts, and to provide information about Waymarks, Route Adventures and other places and attractions in your close vicinity.
- Verify your identity and protect your account security, in compliance with laws, regulations, and other legal obligations
- Enable navigation and scenic route suggestions
- To provide you with access to sensitive and personalised features
- Detect and prevent fraud, misuse, and illegal activity on the Platform.
- To sync your preferences, history, and saved content across devices, so as to enable community engagement (e.g., posts, routes, chat, etc.).
-- Access to certain Scenic services may require permission to use your device's GPS, camera, media library, and notifications. These are requested with your consent and can be managed in your device settings at any time.
- To use User content as part of our advertising and marketing campaigns to promote the Platform.
- To infer additional information about you, such as your age, gender, and interests.
- To enforce our Terms of Use, Community Guidelines, and other conditions and policies.
- For any other purposes disclosed to you at the time we collect your information pursuant to your consent.
Profiling: We do not engage in profiling, which results in legal or similar significant effects, as defined under applicable law.

How We Share and Publicly Disclose Your Personal Information

We are committed to maintaining your trust. While Scenic does not sell your personal information or share your personal information with third parties where legal restrictions apply, for purposes of cross-context behavioural advertising or otherwise, we want you to understand when and with whom we may share the Information We Collect, and for what purpose: for a. we have authorised it, b. you requested it yourself, or c. it is legally necessary for business purposes.

We may share your account information, device information, and location information with partners and other third parties to ensure the smooth completion of the services we provide. However, we will only share your personal information for legitimate and justifiable purposes, and only the personal information necessary to provide the services. We will assess the legality, legitimacy, and necessity of third parties collecting your personal information, and require third parties to process your personal information within the scope of your authorisation and consent, and to take necessary information management measures and technical means to prevent the leakage, damage, loss, or alteration of your personal information.

We share the categories of personal information listed above with service providers and business partners to help us perform business operations and for business purposes, including research, database maintenance, administering technology services, sending communications, advertising and marketing services, analytics, measurement, data storage and hosting, disaster recovery, search engine optimisation, and data processing. These services and business partners may include:
- Cloud hosting
- Analytics: We may partner with third-party analytics providers to analyse App usage. These providers may use device identifiers and engagement metrics to help us deliver more relevant content. Additionally, certain metadata (such as timestamps, geolocation, or contribution credits) may be associated with your content and shown to others based on visibility settings.
-- Visibility & User-Shared Content:
   Scenic enables users to share content, including routes, posts, media, and team events. You control the visibility of your content, whether it's:
     --- Public: visible to all users.
     --- Team-shared: only accessible to participants in a specific team route.
     --- Private: visible only to you.
    We encourage thoughtful use of visibility settings and remind users to avoid posting sensitive personal information in public-facing areas.
- Customer and technical support providers
- Content moderation, and identity verification vendors.
- Regulatory Authorities (if required by law or for legal proceedings)
- Affiliates (if necessary for legal and business operations)
- Credit Agencies
- We may share all of the Information We Collect in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sales, or in the unlikely event of bankruptcy. All data shared with third parties remains within mainland China, unless we have obtained separate and explicit consent from you.
- We may share your personal information as required by laws and regulations, for the resolution of litigation disputes, or when requested by competent administrative or judicial authorities in accordance with the law.

How We Use Cookies, and Similar Technologies

Cookies: With your consent to accept cookies, we, our service providers, and business partners use cookies and other similar technologies (e.g., SDKs, analytics tools, and device identifiers, etc) to automatically collect information. This is to measure and analyse how you use the Platform, including which pages you view most often and how you interact with content, thereby enhancing your experience, improving the platform, along with providing certain features and functionality, and measuring the effectiveness of recommendations and other content on the Platform. We and our partners also use Cookies to promote the Platform on different platforms and websites.

You can clear all cookies saved on your computer or mobile device. You have the right to accept or reject cookies. If your browser automatically accepts cookies, you can modify your browser settings to reject cookies according to your needs. Please note that if you choose to reject cookies, you may not be able to fully experience the services we provide.

We may aggregate or de-identify the above information. Aggregated or de-identified data is not subject to this Privacy Policy.

Other Similar Technologies:
- Web beacons are small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs”, that can recognise Cookies, the time and date a page was viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.
- We may link your contact or account information with your activity on and off our Platform across all your devices, using your email or other log-in or device information. We may use this information to display recommendations on our Platform tailored to your interests, preferences, and characteristics.

We are not responsible for the privacy practices of our service providers and business partners, and the information practices of these parties are not covered by this Privacy Policy.

Data Storage and Retention

Storage Location: We will store the personal information of users collected in the People’s Republic of China in Mainland China, in accordance with laws and regulations. We implement reasonable technical and organisational measures to protect your data, including encryption, secure storage, and access controls.

Cross-Border Transfer: If we need to transfer personal information outside of China, we will:
- Conduct security assessments as required by law.
- Obtain your separate and informed consent as required by law.
- Ensure recipient entities meet data protection standards.

Storage Period: Scenic only retains personal information for the shortest period necessary to fulfil the purposes described in our Privacy Policy, unless a longer retention period is required by applicable laws or regulations. Specifically:
- Account Information (e.g., name, contact details, login credentials): Retained for as long as your Scenic account remains active. If you close your account, we will delete or anonymise your data within 30 days, unless otherwise required by law.
- Route Data, Photos, and Media: Retained for as long as you choose to keep them in your account. If you delete this content, it will be removed from our active systems immediately and from backups within 90 days.
- Usage & Device Data (e.g., app activity, logs, diagnostics): Retained for up to 24 months for performance optimisation, security monitoring, and fraud prevention, after which it will be deleted or anonymised.
- Transaction & Payment Records: Retained for the period required under applicable financial, taxation, or regulatory obligations (generally 5–10 years, depending on jurisdiction).
- Legal or Compliance Records: Retained only for as long as required under applicable laws, regulations, or legal proceedings.
- However, we may adjust the retention period for personal information in the following circumstances:
  -- To comply with applicable laws, regulations, and other relevant provisions (for example, the E-commerce Law stipulates that product and service information and transaction information must be retained for at least 3 years from the date of completion of the transaction).
  -- To comply with court judgements, rulings, or other legal procedures
  -- To comply with the requirements of relevant governments agencies or legally authorised organisations.
  -- For purposes reasonably. necessary to maintain public interest and to protect the personal and property safety of other legitimate rights and interests of Scenic platform users, ourselves or our affiliated companies, other users, or employees.

Data Deletion: Under the Personal Information Protection Law (PIPL), you have the right to request the deletion of your personal information in the following circumstances:
- The agreed purpose of processing has been achieved, cannot be achieved, or is no longer necessary.
- You withdraw your consent to processing.
- You terminate your Scenic account.
- We cease providing Scenic services.
- Our handling of your data violates laws, regulations, or our agreement with you.
When you request deletion, we will respond within 15 working days and either delete or anonymise your personal information, unless retention is required by law (e.g., financial audits, regulatory compliance, dispute resolution).
- How to request deletion:
  -- In-app Settings: Go to Settings > Journey > and select Delete Account
  -- Contact Us: Email our Data Protection Officer at privacy@scenicnav.com with your account details and request.
- In the following circumstances, certain personal information cannot be deleted immediately:
  -- Retention is required to comply with legal or regulatory obligations.
  -- Retention is required to protect the public interest, national security, or legitimate investigations.
  -- Retention is required to exercise or defend legal claims.

In these cases, we will securely store your data and isolate it from further processing until it can be deleted.

Protection of Minors

Our services are not directed at individuals under the age of 18. If you are a minor under the age of 18, or if you do not meet other legal requirements for engaging in user activities, please do not use this platform in accordance with legal and policy requirements, or read tis policy under the supervision and guidance of your guardian, and only use this platform after ensuring that your guardian agrees to the content of this policy.

Scenic will not actively or directly collect personal information from minors.

If there is evidence that a minor has registered for and used our services without the consent of their guardian, the guardian can contact our Data Protection Officer at the dedicated email childsafety@scenicnav.com, and we will delete the relevant minor’s personal information as soon as possible after verification.

Your Rights Regarding Your Personal Information

Under the Personal Information Protection Law of the People’s Republic of China, you have the following rights regarding your personal information:

- Access your data.
- Request correction or deletion, and withdraw consent at any time.
- Object to automated decision-making.
- Request an explanation of data use policies.
- You can exercise these rights by contacting our Data Protection Officer (DPO) at privacy@scenicnav.com.

Changes to This Policy

We may update this policy based on updates to our platform products, features, and relevant legal and regulatory requirements. These updates will form part of this policy. Your continued use of the Platform after changes indicates acceptance of this policy. We will notify you of material changes via in-app notification or email, along with updating the “Last Updated” date at the top of the new Privacy Policy. We recommend that you review the Privacy Policy each time you visit the Platform to stay informed of our privacy practices.

Contact Us

For any privacy-related inquiries or to exercise your rights under the Privacy Protection Law, please contact our Data Protection Officer (DPO) at: privacy@scenicnav.com or call our hotline at 400-822-5665 / Weiye Dexin AI Industrial Park, Puyan Street, Binjiang District, Hangzhou City, Zhejiang Province.

Other

Any disputes arising from this policy may be resolved amicably by contacting us through the contact information provided in this policy, or by filing a lawsuit with the Binjiang District People’s Court of Hangzhou City, Zhejiang Province.