Privacy Policy

Effective Date: January 14, 2026

Thank you for choosing "Steady Browser: Stable & Smart" (hereinafter referred to as "this Browser") for web browsing, information retrieval, content caching and related network services. We attach great importance to the privacy and security of your personal data. This Privacy Policy will detail the specific processes by which this Browser collects, uses, shares, stores and protects your personal information, as well as the data-related rights you are legally entitled to. Your access to or use of this Browser indicates that you have read, understood and accepted all terms and provisions contained in this Policy.

We commit to complying with all applicable privacy laws and regulations, including but not limited to the California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act (VCDPA) and other regional data protection relevant provisions, to ensure that your personal information is processed legally, compliantly and securely.

1. Information about the Data Controller

If you have any questions regarding the processing of your personal information, you may contact us through the following method:

• Email: [email protected]

2. Information We Collect

To implement the core web browsing function, ensure service stability and optimize user experience, we only collect information that is "necessary to achieve the intended purposes" and do not collect irrelevant personal data. The specific information collected is as follows:

1. Device-Related Information
2. Necessary Device Identifiers: To adapt to different devices and ensure the accurate operation of browsing functions, we will collect your device identifiers (such as Android ID, iOS Advertising Identifier). These identifiers are only used for unique device identification and are not associated with personal identity information.
3. Basic Device Parameters: Including device model, operating system version, screen resolution, network type (e.g., Wi-Fi/5G), browser kernel version and available storage capacity. Such information is used to ensure the compatibility and stability of this Browser under different hardware and network environments, and to avoid page loading abnormalities and functional failures caused by device or network incompatibility.
4. Browser Usage Information
5. Core Usage Data: Records of your operational behaviors when using this Browser, such as web browsing history (including visited URLs and browsing duration), bookmark addition and management records, search keywords (only used to optimize search results and not associated with identity information), cache cleaning and Cookie management operations, and the usage frequency of commonly used functions (e.g., "Incognito Browsing", "Ad Blocker").
6. Diagnostic and Fault Data: When this Browser encounters problems such as crashes, page freezes, or loading failures, anonymized fault logs (excluding personal identity information and browsing content) will be automatically collected, including error codes, the URL of the page when the fault occurred, and device network status. Such logs are used to locate and fix software vulnerabilities and improve browsing stability and security.
7. Other Optional Information

Only with your active consent may we collect feedback information you provide, such as:

• Problem descriptions (e.g., "Webpage fails to load", "Ad blocker is invalid") and improvement suggestions you submit via the "Feedback" function within the Browser;
• Information you provide when voluntarily participating in user experience surveys (e.g., satisfaction ratings for functions, demand suggestions for "Night Mode", "Reading Mode", etc.).

1. Information Explicitly Not Collected

We will never collect information about children (i.e., any personal information of minors under the age of 13). If we discover that we have inadvertently collected information about a minor, we will immediately terminate the service, delete all relevant data within 7 working days, and will not use such data for any other purposes.

In addition, we will not actively collect your web content data (such as form information filled in webpages, login accounts and passwords). Only when you enable the "Form Auto-Fill" function and give active authorization will we temporarily store the fill-in information you provide (such as common addresses, contact information), and such information is only stored locally on your device and will not be uploaded to the server.

3. How We Use Your Information

We strictly adhere to the "purpose limitation" principle, and the collected information is only used for the following legitimate purposes, with no use beyond the specified scope:

1. Provision of Core Browsing Services
2. Implementation of Web Browsing Function: Optimize page loading strategies based on device information and network parameters (e.g., compressing images for weak network environments), quickly load frequently visited webpages based on browsing history records, and synchronize cross-device bookmarks for you through bookmark data (requires you to enable "Cloud Sync" and authorize), helping you use the browsing service conveniently and smoothly.
3. Guarantee of Browsing Security: Identify abnormal access behaviors (e.g., frequent access to risky URLs by the same device within a short period) by combining device identifiers and usage data, and filter malicious ads and phishing pages through the ad blocker function to protect your device security and information security.
4. Optimization of Personalized Services: Based on your usage habits (e.g., frequently visited fields, high-frequency use of "Reading Mode"), push tailored optimization suggestions (e.g., "Detected that you often browse news, do you want to enable the 'News Aggregation' function?"), or synchronize your browsing history across devices when you enable "History Sync" to improve operational convenience.
5. Service Improvement and Optimization
6. Function Iteration: By analyzing usage data, identify high-frequency user needs (e.g., high usage rate of the "Ad Blocker" function), prioritize the optimization of relevant functions (e.g., improving ad recognition accuracy), or add functions urgently needed by users (e.g., upgrading "Privacy Protection Mode").
7. Performance Enhancement: Based on device parameters and fault logs, fix compatibility issues (e.g., "video playback stuttering" on specific device models), optimize browser startup speed, page loading time and memory usage, and improve the overall user experience.
8. Customer Support Services

When you feedback problems via email, we will combine the device information and usage scenarios you provide (e.g., "Cannot save bookmarks after enabling Incognito Browsing") to quickly locate the cause of the problem and provide an accurate solution (e.g., guiding you to enable the "Save Bookmarks in Incognito Mode" permission).

1. Legal Compliance and Rights Protection

Where required by laws and regulations, your information may be used to:

• Respond to legal procedures such as court subpoenas and administrative orders;
• Protect the legitimate rights and interests of this Browser and its users (e.g., responding to malicious attacks, phishing website reports, and preventing damage to user devices or data).

4. Rules for Data Sharing and Transfer

We strictly adhere to the "minimum necessity" and "confidentiality obligation" principles and will never sell or rent your personal information to third parties for marketing purposes. Your information may be shared or transferred only in the following circumstances:

1. Sharing with Third-Party Service Providers

Only to achieve the purposes stated in this Policy will we share information with third-party partners that provide technical support for us. We will sign a Data Processing Confidentiality Agreement with them and require them to comply with the following obligations:

• Process data only in accordance with our instructions and not for their own purposes;
• Adopt security measures no less rigorous than those of this Browser to protect data;
• Not retransfer data to other third parties (except with your consent or as required by law).

Common scenarios for sharing include:

• Server Hosting Service Providers: Share anonymized copies of device information and usage data to ensure the stable operation of the Browser server (e.g., traffic load balancing, cross-regional node scheduling).
• Data Analysis Service Providers: Share usage data that does not contain personal identity (e.g., function usage rate statistics, page loading time data) to generate user experience analysis reports and assist us in optimizing functions and performance.
• Security Service Providers: Share abnormal access behavior data (e.g., risky URL access records) to update the malicious website database and improve the Browser's security protection capabilities (e.g., real-time interception of phishing pages).

1. Sharing Required by Law

In the following legal circumstances, we may disclose your information to competent authorities:

• Comply with applicable laws, regulations, or administrative orders;
• Respond to legitimate investigations or official requests from government agencies (e.g., public security organs, market supervision departments);
• Protect the legitimate rights and interests of this Browser, its users, or the public (e.g., responding to cyber attacks, reporting illegal webpage content).

1. Data Transfer in Business Transfers

If we undergo changes such as business mergers, acquisitions, or asset sales, your personal information may be transferred to the new entity as part of the transaction assets. However, we will require the new entity to continue complying with all terms of this Privacy Policy; if there are major changes to the Policy terms, we will notify you via Browser pop-ups or other means and obtain your consent.

5. Your Statutory Rights

Pursuant to applicable privacy laws and regulations (including but not limited to CCPA, VCDPA, and GDPR), you are legally entitled to the following data-related rights, and we will facilitate the exercise of these rights for you:

1. Basic Rights (Applicable to All Users)
2. Right to Know: You have the right to know whether we collect, use, or share your personal information, as well as the categories of collected information, purposes of use, and recipients of shared information (detailed explanations may be obtained by reviewing this Policy or contacting customer service).
3. Right of Access: You have the right to request us to provide a copy of your personal information stored in our system (e.g., feedback records you submitted, device information, cloud-synced bookmark data).
4. Right to Rectification: If you find that your personal information (e.g., contact information provided when submitting feedback, incorrect links in cloud bookmarks) is inaccurate, you may request us to rectify it.
5. Right to Erasure: You have the right to request us to erase your personal information in the following circumstances:
6. The purpose for collecting the information has been achieved (e.g., you no longer use this Browser and have disabled cloud sync);
7. You withdraw your prior consent (e.g., withdraw "Cloud Sync" authorization);
8. Our processing of the information violates laws and regulations.
9. Right to Withdraw Authorization: You may withdraw authorization for permissions such as "Storage", "Location Information (only used for locating local services)", and "Cloud Sync" through your device's system settings (e.g., "App Management - Steady Browser: Stable & Smart - Permissions") or in-Browser settings (e.g., "Settings - Privacy & Security - Cloud Sync"). Withdrawal of authorization may affect the use of certain functions (e.g., inability to sync bookmarks across devices after withdrawing "Cloud Sync" authorization).
10. Right to File a Complaint: If you believe that our information processing practices infringe upon your legitimate rights and interests, you have the right to file a complaint with the local data protection authority (e.g., the U.S. Federal Trade Commission (FTC), EU data protection authorities).
11. Additional Rights for California Users (Pursuant to CCPA)

In addition to the above basic rights, residents of California (as defined by CCPA) are entitled to the following additional rights:

• Right to Request Disclosure: You have the right to request us to provide, free of charge, once per year, "the categories of your personal information collected in the past 12 months, their sources, purposes of use, and the categories of information shared with third parties and the names of such third parties."
• Right to Opt-Out: If we engage in "personal information sales" in the future (we do not currently engage in such activities), you have the right to opt out; even in cases involving information sharing, you may request to stop sharing by contacting customer service.
• Supplementary Provisions on the Right to Erasure: When requesting the erasure of personal information, we will erase all information that can be linked to you after verifying your identity, unless retention is required by law (e.g., retention for responding to legal proceedings).

1. Additional Rights for Virginia Users (Pursuant to VCDPA)

In addition to the basic rights, residents of Virginia (as defined by VCDPA) are entitled to the following additional rights:

• Right to Data Portability: You have the right to request us to provide a copy of your personal information in a "machine-readable format" (e.g., CSV file) (such as cloud bookmark data, browsing history records) to facilitate your transfer of such information to another browser or data controller.
• Right to Object to Processing: If we process your information based on "legitimate interests" (e.g., optimizing page recommendations through browsing history), you have the right to object to such processing. We will review your objection and provide feedback within 15 working days (if the objection is valid, we will cease processing).

1. Additional Rights for EU Users (Pursuant to GDPR)

In addition to the above basic rights, residents within the European Union (referred to as "data subjects" as defined by GDPR) are entitled to the following exclusive rights in accordance with the General Data Protection Regulation (GDPR):

• Right to Obtain Details of Data Processing: You have the right to request us to explicitly inform you whether your personal information is being processed; if processing is taking place, you are entitled to detailed information about the purposes of processing, the legal basis for processing (e.g., "obtaining your consent," "performing a contractual obligation," "based on legitimate interests"), the specific categories of personal information, the recipients of the information (especially recipients outside the EU), and the retention period of the information (if there is no fixed period, the criteria for determining the period shall be explained).
• Right to Restrict Processing: You have the right to request us to suspend the processing of your personal information (retaining only the right to store it) in the following circumstances:
• During the period when you dispute the accuracy of your personal information and we are verifying it;

• When the processing is unlawful, but you do not wish the information to be erased and only request that processing be restricted;
• When we no longer need the information for processing purposes, but you require it to be retained for the purpose of responding to legal proceedings;
• During the period when you have exercised the right to object to processing and we are reviewing the validity of the objection;

During the period of restricted processing, any operation other than storage of the information shall require your explicit prior consent, or shall be conducted to fulfill a legal obligation, protect the legitimate rights and interests of others, or safeguard the public interest.

Right to Object to Automated Decision-Making and Profiling: If we make decisions about your personal information through an automated system (without human intervention) (e.g., determining your service usage rights based on data analysis), and such decisions may have a legal effect on you or significantly affect you, you have the right to object to such decisions. You also have the right to request us to re-review the decision result through human intervention, explain the basis for the decision, and obtain an opportunity for reassessment. If profiling (assessing your personal characteristics through information analysis) is conducted based on "legitimate interests" or "performance of a contract," you also have the right to object.

Right to Withdraw Consent Immediately: If you previously authorized us to process your personal information based on "consent" (e.g., authorizing "Cloud Sync"), you have the right to withdraw such consent at any time, and the withdrawal shall have retrospective effect (after withdrawal, we shall no longer process the information based on the original consent; the information already processed shall be properly disposed of in accordance with legal requirements, unless otherwise specified by law). The method for withdrawing consent shall be as convenient as the method for granting consent, and you may submit a withdrawal request directly via email or through the in-Browser settings (if available).

Right to Object to Cross-Border Data Transfers: If we need to transfer your personal information to a recipient outside the EU (e.g., a cloud server provider in a non-EU region), and that region has not been recognized by the European Commission as having an "adequate level of data protection," you have the right to object to such transfer. We shall explain to you the supplementary measures adopted to ensure data security (e.g., signing EU Standard Contractual Clauses, adopting Binding Corporate Rules). If you still object to the supplementary measures, you may further file a complaint with a data protection authority within the EU.

Right to Exercise Rights Free of Charge and Language Guarantee: When you exercise the above GDPR-related rights, we will, in principle, provide services free of charge (only when a request is obviously unfounded, repetitive, or exceeds a reasonable scope may we charge a reasonable fee or refuse to process the request, and we shall provide a written explanation of the reasons and the fee calculation standards). Additionally, you may choose to submit your request in English or the official language of the EU member state where you reside, and we will provide feedback on the processing result in the same language within 15 working days (if the situation is complex and requires an extension, the maximum extension period shall not exceed 30 working days, and we shall inform you of the reason for the extension in advance).

1. Methods for Exercising Rights

You may exercise the above rights through the following method:

Send an email to the Data Protection Officer at [email protected], specifying "Request to Exercise Rights" + specific needs (e.g., "Access Cloud Bookmark Data," "Delete Browsing History").

6. Data Retention Rules

We adhere to the "minimum necessary retention period" principle for retaining your personal information, with specific retention periods as follows:

1. Device Information and Browser Usage Information: Retained only for "the period necessary to achieve the intended purpose," i.e.:
2. If you continue to use this Browser and enable "Cloud Sync," the bookmark, browsing history and other data stored in the cloud will be retained for 12 months after your last sync, and will be automatically anonymized (e.g., deleting identity-associated identifiers) upon expiration; the browsing history and cache data stored locally will be automatically cleaned according to your Browser settings (e.g., "Settings - Privacy & Security - Auto-Cleanup Cycle"), and will be retained for 6 months by default if not set.
3. If you stop using this Browser (no activity for 18 consecutive months), all cloud data will be deleted within 30 working days, and local data will be managed by your device's system (we do not actively obtain or retain it) (except where retention is required by law).
4. Feedback and Survey Information: Retained for 6 months after "the problem is resolved/the demand is addressed," after which it will be automatically deleted.
5. Information Required to Be Retained by Law: If data retention is required to respond to legal proceedings or comply with regulatory requirements, the data will be retained until the expiration of the legal retention period and then deleted.

7. Legal Bases for Data Processing

Pursuant to applicable privacy laws and regulations, the legal bases for our processing of your personal information include the following circumstances:

1. Your Consent: For "optional information" (e.g., feedback information) and "non-essential permission authorizations" (e.g., "Cloud Sync," "Location Information Access"), your explicit consent is the legal basis for processing; you may withdraw your consent at any time, which will not affect the legality of processing prior to withdrawal.
2. Performance of Contractual Obligations: Processing device information and usage information is a necessary step to provide you with web browsing services (i.e., the service contract between you and us), which complies with the legal requirement of "performing a contract."
3. Legitimate Interests: Processing information to ensure browsing security (e.g., intercepting malicious webpages) and optimize service experience (e.g., improving loading speed based on browsing habits), without impairing your privacy rights and interests, complies with the "legitimate interests" principle.
4. Legal Obligations: Processing information to comply with laws and regulations (e.g., responding to network security regulatory requirements, reporting illegal content) constitutes a necessary act of "fulfilling legal obligations."

8. Information Security Protection Measures

We adopt a three-tier security protection system combining "technology + management + physical measures" to ensure that your personal information is not accessed, used, or disclosed without authorization:

1. Technical Security Measures
2. Data Transmission Encryption: Personal information (such as cloud-synced bookmark data) is transmitted using SSL/TLS protocol encryption, and local information such as browsing history and cache data is stored using AES encryption to prevent theft during transmission and storage.
3. Security Verification Mechanism: When enabling the "Cloud Sync" function, you need to confirm your identity through your account password or two-factor authentication (e.g., SMS verification code) to prevent unauthorized access to your synced data by others.
4. Vulnerability Protection: Regular security vulnerability scans (at least once per quarter) are conducted to promptly fix browser kernel vulnerabilities and data interface vulnerabilities, and prevent hacker attacks and data leakage risks.
5. Management Security Measures
6. Permission Control: Only employees who need access to data for "work purposes" are granted data access rights (e.g., customer service personnel may only view user feedback and not user browsing history), and all access operations are logged for traceability.
7. Employee Training: Regular data security and privacy protection training is provided to employees, requiring them to strictly abide by confidentiality agreements and prohibiting the disclosure or tampering of user information.

9. Description of Third-Party Services

This Browser may integrate a small number of third-party service modules to implement specific auxiliary functions. Third parties will process data in accordance with their independent privacy policies. We carefully select these third-party services and make commercially reasonable efforts to require them to comply with data protection obligations. However, we cannot directly control the operations and behaviors of third parties and shall not be liable for their actions. We recommend that you review their privacy policies in advance:

1. Search Engine Services: If third-party search engines such as Google Search and Baidu Search are integrated, they will process your search keywords in accordance with their own privacy policies. Relevant policies can be found on the official privacy pages of the search engines (e.g., Google Search: https://policies.google.com/privacy);
2. Advertising Services: If third-party advertising modules such as Google Ads (AdSense) and Baidu Ads are integrated, they will process device identifiers and browsing preference data in accordance with their own privacy policies. Relevant policies can be found on the official privacy pages of the advertising service providers (e.g., Google Ads: https://policies.google.com/privacy);
3. Security Detection Services: If third-party malicious URL detection services (such as Tencent Security, 360 Security) are integrated, they will process the accessed URL data in accordance with their own privacy policies. Relevant policies can be found on the official privacy pages of the security service providers.

10. Updates to This Privacy Policy

We may update this Privacy Policy under the following circumstances:

1. Changes in laws, regulations, or regulatory requirements;
2. Major adjustments to the functions or data processing methods of this Browser (e.g., adding a "Cross-Device File Transfer" function);
3. Improvements in user needs or privacy protection standards.

After this Policy is updated, we will notify you via Browser startup pop-ups and the "Settings - About - Privacy Policy" page; your continued use of this Browser indicates that you accept the updated terms.

11. Contact Information

If you have any questions, comments, or complaints regarding this Privacy Policy, you may contact us through the following method:

• Email: [email protected]

We will respond to your inquiry within 15 working days of receipt. For complex matters (e.g., cloud data deletion, privacy complaint handling), we will complete the processing and provide feedback within 15 working days.