We're Updating Our Operating Entity

Dear User,

To support our future business development and provide you with better services, the operating entity of 开桥 will officially change from 开桥 openqiao to 开桥 openqiao, effective on September 9, 2026 (in 7 days).

What You Need to Know

• Uninterrupted Service: This transition will not affect your daily use. All features, services, and product operations will continue as normal.
• Account & Data Security: Your account details, historical data, and associated benefits will remain completely unchanged and securely transferred to the new entity.
• Updated Legal Terms: Along with this transition, we will be updating our Terms of Service and Privacy Policy to reflect the new operating entity. Starting from the effective date, all rights and obligations will be assumed by 开桥 openqiao. We remain strictly committed to protecting your personal data in compliance with all applicable laws.

Review the Upcoming Changes

To ensure full transparency, we have attached the complete, upcoming versions of both our Terms of Service and Privacy Policy at the end of this post. 请scroll down to review the following documents:

• Appendix 1: Terms of Service (Upcoming Version)
• Appendix 2: Privacy Policy (Upcoming Version)

Next Steps

No action is required on your part. By continuing to use 开桥 on or after September 9, 2026, you agree to the entity change and the updated Terms of Service and Privacy Policy.

If you have any questions, concerns, or objections regarding this update, please feel free to contact us before the effective date.

• Contact Support: support@openqiao.com

Thank you for your continued support and trust in 开桥!

Sincerely,
The 开桥 Team

Appendix 1: Terms of Service (Upcoming Version)

Effective Date: September 9, 2026

Operating Entity: 开桥 openqiao

Summary of Key Updates:

1. Operating Entity Update: All rights and obligations previously held by 开桥 openqiao have been transferred to and assumed by 开桥 openqiao
2. [New] Log Data Visibility: Clarified that the workspace console provides visibility into logs for up to 180 days.
3. [New] PayGo Overdraft & Deduction Rules: For usage exceeding prepaid amounts, balances can be displayed as negative numbers. Any subsequent Credit top-up will be applied first to settle the outstanding negative balance.
4. [New] 订阅计划 (Subscription) Usage Restrictions: The 订阅计划 is intended solely for personal Copilot use cases and is strictly prohibited in production environments (including, but not limited to, batch data processing or providing services to third parties). 开桥 reserves the right to audit usage and take necessary enforcement actions.
5. [New] BYOK (Bring Your Own Key) Terms: Users bear sole responsibility if their own API keys are suspended or terminated by upstream providers due to user actions. 开桥 disclaims any and all liability in such events.

开桥 User Agreement

Revised Date: August 25, 2026

Effective Date: September 9, 2026

Thank you for using 开桥! Before you access Our Service, please read the 开桥 User Agreement.

开桥's products and services (referred to as "Our Service") are owned and operated by 开桥 openqiao (referred to herein as "we," "us," or "the Company"). Before using our products and services, the user (referred to as "You"), must carefully and thoroughly read and understand 开桥 User Agreement (referred to as "this Agreement"). Pay special attention to the bolded clauses, including but not limited to those concerning limitations or exclusions of the Company's liability, restrictions on your rights, and the governing law and dispute resolution mechanisms.

This Agreement is jointly entered into by You and the Company and is legally binding on both parties. The content of this Agreement includes the main text and various specific agreements and service rules that the Company has already published or may publish in the future. For example, we may enter into other specific agreements or rules with You when You use certain specific features of Our Services. In the event of a conflict between this Agreement and other specific agreements, the provisions of the other specific agreements shall prevail. The aforementioned agreements constitute an inseparable part of this Agreement and have the same legal effect as the main text.

Unless You have read and accepted all the terms of this Agreement, please do not use Our Service. Your access or use of Our Service via web pages, browser plugins, or any other means will be deemed as your acknowledgment, understanding, and full acceptance of the entire content of this Agreement, thereby establishing this legal relationship with us. We may update this Agreement from time to time in accordance with applicable laws, regulations, or business developments. Changes will be announced through website pop-ups, in-service notifications, or other appropriate means. 请regularly review the latest terms of the Agreement. If You do not accept the content of the updated Agreement, please immediately stop using Our Service. Your continued use of our Service will be considered as your consent to and acceptance of the updated Agreement.

I. Definitions

Unless otherwise stated, the terms below shall have the following meanings in this Agreement:

1.1 We / "The Company": Refers to 开桥 openqiao, the operator of the 开桥's products and services, which is a company incorporated under the laws of Singapore, with its registered place at 11 COLLYER QUAY, #05-06C, THE ARCADE, SINGAPORE 049317.

1.2 "Our Service" / "开桥": Refers to Our Service we provide via the 开桥 website (https://openqiao.com/), which curates and offers access to multiple top-tier algorithm models for users.

1.3 "User" / "You": Refers to any individual, organization, or enterprise that accesses or uses Our Service.

II. Regarding our Service

2.1 Our Service include the products and services we provide to You via our website or other formats that may emerge with technological advancement and business adjustments. As our technology, models, and products continuously evolve and relevant laws and regulations change, we may upgrade, modify, suspend, or terminate Our Service, and may conduct internal or external testing for new service features.

2.2 You must be at least 18 years old or the age of majority in your jurisdiction, whichever is higher, in order to access or use Our Service. If You are younger than 18 years old or the age of majority in your jurisdiction, You must not access or use Our Service.

2.3 The LLM underpinning our Service include:

• Google: Gemini series
• OpenAI: GPT-o4 Mini, GPT-4 series, GPT-4o series, GPT-5 series
• Anthropic: Claude series
• xAI: Grok series
• DeepSeek: DeepSeek series
• Moonshot AI: Kimi series
• Qwen: Qwen3 series
• Z.AI: GLM series
• Ant Group: Bailing series

请refer to Our service page at https://openqiao.com/models for details.

These large language models (LLM) are provided by the companies listed above and integrated into Our Service. You must ensure compliance with the terms and conditions set by the respective LLM providers, which may include but are not limited to usage restrictions, data protection policies, intellectual property rights clauses, and other relevant requirements. You are responsible for familiarizing yourself with and adhering to the requirements of these third-party LLM providers.

The Company shall not be held liable for any consequences arising from your failure to comply with the terms and conditions of these third-party LLM providers. You shall bear all risks and liabilities resulting from any violations of the third-party LLM provider's policies.

Additionally, due to ongoing technological and business advancements, the integrated LLM services and related algorithm models may be modified, replaced, or adjusted at any time. We will notify You of any significant changes as needed, but we do not guarantee that any specific LLM will remain part of our Service in the long term.

III. Account Registration and Management

3.1 Users must first register a user account to use our Service. In accordance with relevant regulations, users are required to register using their personal information. Users may terminate their account usage at any time by following the instructions provided within our Service. We reserve the right to retain or terminate accounts as stipulated in this Agreement.

3.2 You acknowledge and agree that all information provided during registration is truthful, accurate, lawful, and valid, and that You consent to this Agreement and other rules or policies. You warrant that the 开桥 account information You set does not contain any content that violates national laws, regulations, policies, this Agreement, or related service rules or policies; You shall not impersonate others (例如, using others' names, trademarks, images, 等) without authorization. You shall not maliciously use the account to cause misunderstanding by others. Otherwise, we reserve the right to immediately suspend services, and You shall bear all legal liabilities arising therefrom.

3.3 You shall safeguard your account and login credentials to prevent unauthorized access by others. Without our consent, You may not lend, lease, transfer, gift, sell, inherit, or otherwise permit others to use your account. Furthermore, You shall not engage in malicious registration activities such as frequent or bulk registration of 开桥 accounts. You must promptly notify us upon discovering any unauthorized use or suspicious activity that may be unlawful. We assume no liability for losses resulting from your failure to comply with this requirement.

3.4 Your use of our Service must comply with the law. You are solely responsible for all activities under your account, including but not limited to inputting instructions, generating outputs, and uploading attachments. You must independently evaluate the use of content and features and bear all risks associated with such use. We are not liable for any loss or damage caused by your actions.

IV. Product and Service Guidelines

4.1 Subject to this Agreement, the Company grants You a limited, non-transferable, non-exclusive license to use Our Service, including related websites. All rights not expressly granted herein are reserved by the Company. Your exercise of such rights requires separate permission from the Company. The Company's failure to enforce any right hereunder does not constitute a waiver of that right.

4.2 As a 开桥 user, You agree to comply with the following usage guidelines when using Our Service:

4.2.1 Network and System Security

You shall not violate applicable laws and regulations or interfere with, disrupt, or attack Our Service, or the Company's systems, networks, models, or other components. You commit to refraining from the following activities that compromise network and system security:

(1) Unauthorized Network Access: Unauthorized use of data or access to servers/accounts; probing, scanning, or testing vulnerabilities in the system or network of Our Service; intentionally disseminating malware, viruses, or other harmful code;

(2) Disrupting Services: Reverse engineering (including disassembly, decompilation, 等) without permission; modifying, damaging, or interfering with product functionality; altering related web pages or interfaces without authorization;

(3) Data Theft and Misuse: Unauthorized imitation of the appearance or functionality of Our Service; copying, deleting, altering, or stealing information content directly or indirectly by any means; scraping data, collecting, or analyzing user behavior, operational data, 等, via automated tools;

(4) Other activities that compromise system security.

4.2.2 Content Compliance

You shall not input, generate, or disseminate illegal or harmful information in violation of applicable laws, regulations, and regulatory requirements when using Our Service. Prohibited content includes, but is not limited to:

(1) Explicit Content: Content containing nudity, sexual acts, or explicit imagery.

(2) Violent or Graphic Content: Images or descriptions depicting violence, gore, or other graphic brutality.

(3) Hate Speech and Discrimination: Language or imagery that incites hatred, discrimination, or violence against individuals or groups based on race, ethnicity, nationality, religion, gender, sexual orientation, disability, or other protected characteristics.

(4) Harassment and Bullying: Content that intimidates, disparages, or harasses individuals or specific groups.

(5) Misinformation and Disinformation: Deliberately misleading or fraudulent information, or impersonation of individuals or organizations.

(6) Illegal Activities: Content promoting illegal acts or violations of laws and regulations.

(7) Spam and Malware: Unsolicited promotional or commercial messages, or content containing malicious software.

(8) Infringement or Misappropriation of Others' Intellectual Property Rights.

4.2.3 Prohibited Misuse

In addition to adhering to the above guidelines, You shall not, without the Company's permission, use Our Service for the following illegal or improper activities:

(1) Any purpose that violates applicable laws or infringes upon the legitimate rights and interests of third parties;

(2) Any purpose that may cause serious harm to public interests, health, safety, psychology, or social order, or violates scientific ethics;

(3) Engaging in activities that infringe intellectual property rights, trade secrets, or other acts against fair competition and business ethics;

(4) Selling, leasing, sublicensing, or otherwise transferring Our Service, or profiting by violating the terms of this Agreement;

(5) Any other illegal, potentially illegal, or activities that may harm or interfere with the Company's operation of Our Service.

V. Personal Information Protection

5.1 We fully respect the protection of your personal information. You can read the 开桥 Privacy Policy to understand the purposes, methods, and scope of our collection and use of your personal information while You use Our Service, your rights regarding your personal information, and the security measures we implement to protect your information.

5.2 You may access to your user data, including but not limited to conversation history, usage logs, and uploaded content for a maximum period of 180 calendar days from the date of generation and/or relevant interaction. For more model usage records detail, please refer to 开桥 Privacy Policy. Notwithstanding the above, the Company may retain your usage data for longer periods when:

(a) Required by applicable law, regulation, or legal process;

(b) Necessary to enforce this Agreement and for the Company's legitimate rights;

(c) Required for security incident investigation or fraud prevention.

VI. Intellectual Property and Licenses

6.1 As the developer and operator of Our Service, the Company owns all intellectual property rights (including but not limited to copyrights, trademarks, patents, and other proprietary rights) in all content provided within Our Service (including but not limited to software, technology, models, code, user interfaces, electronic documentation, 等). All rights not expressly granted herein are reserved by the Company. Without the Company's permission, You may not use, exploit, copy, or transfer these in any manner.

6.2 To the extent permitted by law, You retain ownership, intellectual property rights, and other relevant rights to the content You input while using Our Service. Subject to your authorization and compliance with relevant laws, regulations, and the terms of this Agreement, we may use such content to provide, maintain, develop, and improve Our Service.

6.3 You warrant that the content You input while using Our Service is either your original creation or You possess the legal authorization for its use, and that it does not infringe upon any third party's intellectual property rights, portrait rights, reputation rights, name rights, privacy rights, personal information rights, trade secrets, or other legitimate rights and interests.

6.4 Without permission, You shall not use any trademarks, service marks, trade names, domain names, website names, or other distinctive brand features of the Company or Our Service under any circumstances. Without the Company's prior written consent, You shall not display, use, apply to register as a trademark, register as a domain name, or otherwise handle these identifiers, either alone or in combination.

6.5 Notice and Procedure for Making Claims of Copyright Infringement

6.5.1 If You believe that your work has been copied in a way that constitutes copyright infringement, You may provide written notice to us in the form prescribed by and containing the information required under the Copyright Act 2021 of Singapore, to be submitted to our designated representative, as follows:

• Name: 开桥 openqiao
• Email: bd@openqiao.com

6.5.2 We will only process notices in the English language that comply with the requirements under the Copyright Act 2021 of Singapore, other applicable laws, and these Terms. Any notices that do not comply with the above may not be processed.

6.5.3 We will duly consider all notices submitted in accordance with the requirements above. You agree that You shall not take any legal action or exercise any legal remedy You may have against us in respect of any allegedly infringing material, unless You have first given us notice in accordance with the requirements above, and a reasonable and sufficient opportunity to remove the allegedly infringing material following your notice to us. Where we remove the allegedly infringing material in response to your notice, You agree not to exercise and You hereby waive, any right of action against us under applicable law which You may have in respect of any infringing material appearing on Our Service prior to such removal by us.

You agree and acknowledge that we have no control and are not responsible or liable for any content or material on third-party platforms or services.

VII. Liability and Limitation of Liability

7.1 You understand and agree that Our Service is developed based on new technologies like generative AI. We are continually improving our technology, models, and products. The output of our Service is inherently unpredictable and may generate inaccurate, inappropriate, or erroneous code or information. Such outputs do not represent the Company's position or views. You must evaluate the output content, use it appropriately, and bear all risks and responsibilities associated with its use.

7.2 Under no circumstances shall the Company be liable for any inability to access Our Service, service interruptions, leakage, delay, stagnation, or error of information and data, or failure or delay in providing services, resulting from: unstable third-party factors like network connection failures, power outages, hacker attacks, internet viruses, adjustments by network operators; force majeure events such as natural disasters, strikes, riots, wars, governmental actions, judicial or administrative orders; or any other causes beyond the Company's reasonable control.

7.3 To provide You with better products and services, we may periodically perform maintenance, updates, and introduce new features. During testing phases of new features, service instability may occur. Except as expressly required by law, the Company makes no guarantees regarding the stability or performance of features in testing phases and assumes no liability for such matters.

7.4 The Company is not responsible for any services or content provided by third parties (if any), nor for any loss You incur due to your use of such third-party services or content.

7.5 The Company service of 订阅计划 (Subscription) is designed and licensed for personal Copilot use only, which is primarily for personal assistance and cannot be shared, used in production environment settings, for data processing at scale and/or automated workflows. The Company reserves the right to audit your usage data, including but not limited to API call patterns, token consumption, request frequency, and service endpoints accessed. If the Company find, at its sole discretion, that You have violated the aforementioned restriction, the Company reserves the right to seek damages for any losses resulting from unauthorized commercial use.

7.6 The Company offers a Bring Your Own Key (BYOK) option that allows You to use your own API keys from third-party AI providers with 开桥 services, and You acknowledge and agree that You are solely responsible for obtaining, maintaining, and securing your API keys and to comply with the terms of service and acceptable use policies of the respective third-party providers. The Company disclaims all liability for any interruption, suspension, or termination by the third-party provider, and You agree to indemnify and hold harmless the Company from any claims, damages, losses, or expenses arising from your use of BYOK.

7.7 You acknowledge that if You violate this Agreement or other service guidelines or policies, we have the right to take actions against You, including warnings, requests for rectification within a time limit, restriction of account functions, suspension of use, account closure, prohibition of re-registration, or deletion of related content. We will preserve records of suspected illegal activities or crimes and report them to relevant authorities or cooperate with investigations as required by law. You shall bear all legal liabilities or any claims, demands, or losses asserted by third parties arising from your breach. If the Company suffers any losses due to your breach, You shall be liable for compensation.

7.8 You agree that You shall bear all losses (including but not limited to infringement against third parties, compensation for damages) resulting from your breach of this Agreement or relevant laws and regulations. Unless otherwise stated in this Agreement, the service interface, or expressly required by law, the Company shall not be liable for any losses You incur arising from the use of Our Services.

VIII. Fees

8.1 Unless otherwise agreed by the parties, You shall be responsible for paying us the fees incurred by its account at the rates specified on the model pricing page. We may update the published rates, with updates becoming effective the earlier of 30 days after the updated rates are posted by us or User otherwise receives Notice.

8.2 You acknowledge that due to system latency and real-time usage calculation, your Credit balance may temporarily show a negative value ("Overusage") when your consumption exceeds your available Credit and your account balance will display as a negative value until additional Credit is added. Any subsequent Credit top-up You paid will be automatically applied to settle the outstanding negative balance first before being available for new usage. The Company reserves the right to suspend or terminate services until the negative balance is settled.

8.3 Taxes. Fees do not include any taxes, duties, or assessments that may be owed by user for use of Our Service ("Taxes"), unless otherwise specified in the applicable invoice. User is responsible for remitting any necessary withholding Taxes to the relevant authority on a timely basis and providing us with evidence of the same upon request. Where law provides for the reduction or elimination of withholding taxes, including via tax treaty, the parties will collaborate in good faith to do so. For clarity, User must pay us an additional amount (a "Gross-up Payment") sufficient to ensure that we receive the same net amount it would have received if no such withholding or reduction had been required (taking into account any and all applicable Taxes (including any Taxes imposed on the Gross-up Payment itself)).

8.4 If User fails to pay us all amounts due when due, we may suspend or terminate User's access to Our Service. We reserve all other rights it may have regarding the collection of fees.

IX. Refund Policy

You may apply for refund according to the following terms and conditions.

9.1 Refund Rights

9.1.1 Pay-as-you-go: If You chose the Pay-as-you-go to pay us fees, You may apply for a refund of the fees corresponding to the unused PAYG credits that You have paid for, which does not include the premium PAYG credits (the “Unused Paid PAYG Credits”) within twenty-four (24) hours after purchasing. The Premium PAYG credits will be forfeited immediately once You apply for the refund and are non-refundable. No fees will be refund after twenty-four (24) hours after purchasing.

9.1.2 Subscription: if You chose to subscribe for our 开桥 订阅计划, and the fees calculated based on the PAYG pricing rates for the tokens actually consumed as of You send the refund application email (“Consumption Fee”) are less than the subscription fees You have actually paid (“Subscription Fee”), You may apply for a refund of the balance between the Consumption Fee and the Subscription Fee within twenty-four (24) hours after subscription. No fees will be refund after twenty-four (24) hours after subscription.

9.2 Refund Amount

9.2.1 Platform Service Fees: Subject to the compliance with this Agreement, a platform service fees equal to 5% of the refundable amount will be deducted.

9.2.2 Refund Amount: The specific refund amount shall be calculated as follows:

• Pay-as-you-go Fee Refund Amount = fees corresponding to the Unused Paid PAYG Credits × (1 − 5%), in which, Unused Paid PAYG Credits = the total PAYG credits You paid for – the PAYG credits You have used

• Subscription Fee Refund Amount = (Subscription Fee − Consumption Fee) × (1 − 5%)

9.3 Refund Application: 请send your refund application to support@openqiao.com, and provide your account email / account ID, purchase/subscription starting date and time (YYYY-MM-DDHH), purchase/subscription fee amount, current unused credits balance, reason for refund request and any other information we may require from time to time.

9.4 Refund Processing: We will review your refund application within 7 business days of receiving your application email. Eligible refund application will be processed and we will process the refund to your original payment account in the original payment currency via the original payment method in accordance with these terms. Any discrepancies arising from exchange rate fluctuations shall be borne solely by yourself.

9.5 Processing Time: The actual receipt of refunds varies by payment institution and may take an additional 3 to 10 banking business days.

X. Governing Law and Jurisdiction

These Terms and any dispute, action, or claim arising out of or in connection with them, their subject matter, and/or their formation (including tortious or non-contractual disputes, actions, or claims) shall be governed by and construed in accordance with the laws of Singapore. You hereby irrevocably submit to the exclusive jurisdiction of the courts of Singapore.

XI. Modification and Termination of the Agreement

11.1 We reserve the right to modify the terms of this Agreement when necessary. Once amended or changed, the revised terms will be announced via website pop-ups, in-service notifications, or other appropriate methods. 请regularly check for and read the latest terms. If You disagree with the changes, You must actively cancel Our Service. Your continued use of Our Service constitutes acceptance of the modified terms.

11.2 This Agreement will automatically terminate or be rescinded under the following circumstances:

(1) We cease providing Our Service;

(2) Either we or You cease to exist or lose legal capacity due to dissolution, bankruptcy, liquidation, 等;

(3) You request account deletion and it is approved by us, or You otherwise cease using Our Service.

XII. Contact Information

If You discover any illegal activities or violations of this Agreement while using Our Service, or if You have any opinions or suggestions regarding this Agreement or Our Service, You may contact us through the following channels:

• Name: 开桥 openqiao
• Email: bd@openqiao.com

For refund-related inquiries, please contact:

• Email: support@openqiao.com
• Website: https://openqiao.com

(The end)

Appendix 2: Privacy Policy (Upcoming Version)

Effective Date: September 9, 2026

Data Controller / Operating Entity: 开桥 openqiao

Summary of Key Updates:

1. Data Controller / Operating Entity Update: Updated the operating entity from 开桥 openqiao to 开桥 openqiao (including its registered business address in Singapore).
2. [New] Model Usage Records: Clarified the scope of AI model interaction data collected (such as model used, timestamps, and token counts). Confirmed that full inputs/outputs are not retained as part of these records, and interaction logs remain accessible on the website for 180 days.
3. Data Storage & Cross-Border Processing Locations: Clarified that in addition to primary data storage in Singapore, certain data may also be stored or processed in Malaysia to enhance regional service performance and disaster recovery capabilities.
4. Third-Party Service Providers: Explicitly specified the engagement of cloud service providers located in Singapore and Malaysia as authorized sub-processors under strict confidentiality and data protection standards.

开桥 Privacy Policy

Revised Date: August 25, 2026

Effective Date: September 9, 2026

概览

This 开桥 Privacy Policy (this "Policy") will help you understand:

• I. How We Collect Personal Information
• II. How We Store and Protect Personal Information
• III. How We Use Personal Information
• IV. How We Share Your Personal Information
• V. How We Use Cookie, Beacon, Proxy and Other Technologies
• VI. How You Can Exercise Your Rights regarding Your Personal Information
• VII. Statement on User Content
• VIII. Statement on Third Party Liability
• IX. No Intention to Collect Personal Information of Minors
• X. Application and Revision of the Policy
• XI. Notes to Key Terms Used in the Policy

开桥 (referred to as "we", "our" or "us" in this Policy) respects and protects your privacy. We will collect, store, use and/or share your personal information in accordance with this Policy. We will also explain to you, through this Policy, how you may access, update, manage and protect your personal information held by us.

This Policy is closely associated with your use of the services. We suggest you carefully read and understand all terms in this Policy and make choices you deem appropriate. We try to use plain and concise language, and for provisions that are vital to your rights or interests, we use words in bold for your attention. If you do not agree with our policies and practices, please do not use the service.

We will collect, store, use and/or share your personal information as required in order to comply with the requirements of applicable laws and regulations, to provide relevant services and to improve the quality of such services. We will process your personal information in accordance with this Policy to enable you to access quality, convenient and efficient services and to better protect your account.

I. How We Collect Personal Information

In accordance with applicable laws and regulations, we may process your personal information in the following circumstances:

(1) when we obtain your express consent or your deemed consent under applicable laws and regulations;

(2) when it is necessary for the conclusion and performance of a contract;

(3) when it is necessary to fulfill our legal obligations, such as the necessary information required by laws and regulations about anti-money laundering, anti-terrorist financing and real-name management;

(4) when it is directly related to national security or national defense security;

(5) when it is necessary to respond to public health emergencies, or to protect the life, health and/or property safety of natural persons in an emergency;

(6) when it is directly related to a criminal investigation, prosecution, trial or enforcement of judgments, or to recover a debt;

(7) when the personal information has been made publicly available by an individual voluntarily and through other legitimate means (such as legitimate news reports, government information disclosure, 等), and the processing of such publicly available personal information is reasonable and permitted by applicable laws and regulations;

(8) when it is necessary for the improvement of, or maintenance of, secure and stable operation of the services provided, or evaluative purposes such as to discover and deal with failure in the products or services; or

(9) other circumstances provided in applicable laws and regulations.

请note that when we process your personal information in the above circumstances (2) – (9), we may not need to obtain your consent in accordance with, and to the extent permitted by, applicable laws and regulations.

When you use the services, we may need to collect following types of information in order to provide you with relevant services, improve the quality of our services, safeguard the security of your account, and comply with applicable laws and regulations:

Personal Information. To identify our customers, when you register accounts for relevant services on our website, we may collect your name, email address, phone number and other contact information from you.

Usage Information. In order to provide relevant services and to facilitate your access to relevant services, we will store necessary information generated or submitted when you use the relevant services, such as pages you visited and actions you took.

Location Information. We may obtain and preserve information about your computer, such as IP address.

Model Usage Records. When you use AI models through our services, we maintain records of your interactions, which include the specific model used, the date and time of the interaction, and the number of tokens consumed. We do not retain the full content of your inputs or outputs as part of such records; where related content is retained for service continuity, it is handled in accordance with the applicable terms for User Content. These records are available for access through our website within 180 days following the date of the relevant interaction.

II. How We Store and Protect Personal Information

1. We will store and/or transfer your personal information in accordance with applicable laws and regulations. Personal information collected and generated by us about you may be transferred and/or stored outside your country/region of residence. Generally, all data (including Personal Information and User Content) uploaded or transferred by you to us related to your account and product services will be stored in Singapore. In addition, to improve regional service performance and strengthen our disaster recovery capabilities, certain information may also be stored or processed in Malaysia. In carrying out such international transfers, we will follow the requirements of applicable laws and regulations, and will require such overseas recipients or sub-processors of your personal information to ensure that the standard of protection provided by such overseas recipients of personal information is comparable to that under applicable laws and regulations of your country/region of residence.

2. We will only retain your personal information for the period necessary for the purposes set forth in this Policy and within the timeframe required by applicable laws and regulations.

3. We maintain data protection and security. To safeguard your personal information, we are dedicated to exploiting various security technologies and supporting management systems to reduce the risks of your personal information being divulged, corrupted or lost, misused, revised, accessed or disclosed without authorisation, strictly restricting access to the data center and using private network channels and network proxies.

4. We have appointed staff responsible for personal information protection. We have also developed a relevant internal control system, and adopted the authorisation principle of minimal and sufficient use by employees who may have access to your personal information. We systematically monitor the data processing activities of our employees.

5. We have formulated emergency plans for personal information security incidents and regularly arrange relevant internal personnel to receive emergency response training and to conduct emergency exercise, so that they are able to master the responsibilities of their position and the strategies and procedures for emergency response. If, unfortunately, any personal information security incident occurs, we will act in accordance with applicable laws and regulations and, where required, inform you in a timely manner of the basic information and possible impact of the security incident, measures taken or to be taken by us, suggestions for you to take precautions on your own and to reduce risks, remedial measures taken for you, 等

6. While we take information security measures to protect your personal information, please also ensure that you keep your account login name and other identifiers in a safe manner. When you use the services, we will identify you by your account login name and other identifiers. Once you divulge such information, you may suffer from losses and adverse legal consequences against you. If you find that your account login name and/or other identifiers may be or have been divulged, please contact us immediately so that we may take appropriate measures to avoid or mitigate the relevant losses.

7. Upon our customer's termination of using the services, we will stop collecting your personal information, except as otherwise provided by applicable laws and regulations or required by regulatory authorities. If the retention period of relevant personal information required by applicable laws and regulations has not expired or there are other circumstances under which the relevant personal information shall not or need not be deleted according to applicable laws and regulations, we will continue to retain such personal information while ceasing to process such personal information, except for storage and taking necessary security protection measures. If we cease operations, we will promptly stop collecting your personal information, and will inform you of the cessation, and delete or anonymize the personal information held by us.

III. How We Use Personal Information

To comply with applicable laws and regulations, to provide relevant services, to improve service quality and customise your experience, or to safeguard the security of your account, we will use your personal information under the following circumstances:

• provide services;
• contact you regarding the management of any features or functions of the website or service you have registered to use;
• provide you with notifications about your account;
• notify you of changes to our website, policies, terms, or any products or services;
• send you marketing and promotional emails;
• respond to your questions or other requests;
• enable you to participate in interactive features of the website and services;
• customize your experience on the website or service and/or otherwise tailor the content you see when visiting and using the website or service;
• store your user account, registration and profile data, or other personal data;
• track your return visits to and use of the website and services;
• accumulate and report aggregated statistical information related to the website and services and user activities;
• determine which features and services users prefer most, to help us operate, enhance, and improve our website;
• protect your safety while using our website, which requires us to process your personal data to combat spam, malware, malicious activity, or security risks;
• improve and enforce our security measures;
• maintain legal and regulatory compliance;
• enforce compliance with our Terms of Service and other policies;
• investigate and resolve disputes;
• investigate and prevent fraud, abuse, and violations of our Terms of Service and other policies, illegal or criminal activities, unauthorized access to or use of personal data or our systems and networks;
• protect you, others, and our business.

We also use information for any other purposes disclosed to you before you provide personal data or for purposes reasonably necessary to provide the services or other related products and/or services.

We may additionally use your information for research and analysis purposes and to comply with our policies or legal requirements.

IV. How We Share Your Personal Information

1. Sharing of your personal information for providing services

Your personal information will be shared by us with third parties. We may share your information with third parties for commercial purposes, for example to enable them to provide services on our behalf or to assist us in analyzing how the services are used.

Such third parties include (a) our affiliates and other partners, (b) our third party service providers and contractors, (c) our authorised agents, (d) our professional advisers, (e) law enforcement agencies, courts, governmental bodies and regulatory authorities to whom we may be legally required to make disclosures, and (f) any individuals or entities involved in any merger, acquisition, corporate reorganisation, financing or similar transaction involving the sale of all or part of our assets.

We may engage carefully selected third-party service providers, including cloud service providers in Singapore and Malaysia, to process personal information on our behalf. These providers act only on our instructions and are contractually bound to maintain appropriate security and confidentiality measures in accordance with applicable data protection laws.

2. Complaints handling

To perform our legal obligations and to protect the legitimate rights and interests of you and others, we may, when you lodge a complaint about others or are complained by others, provide your name, contact information, and the relevant contents of the complaints to the relevant consumer rights protection authority and/or the regulatory authorities to resolve such complaints or disputes in a timely manner, except where expressly prohibited by applicable laws and regulations.

V. How We Use Cookie, Beacon, Proxy and Other Technologies

For easier user experience, we may identify you through small data files when you visit our website or use any service provided by us, which could save you the trouble of repeatedly entering login information or help to determine whether your account is safe. Such data files may include cookies, flash cookies or other local storages provided by your browser or linked applications (collectively referred to as "cookies"). 请understand that some of our services are only available through cookies. You can change the cookie acceptance level or refuse our cookies if it is allowed by your browsers or browser add-ons. The "Help" section of the toolbar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on settings or by visiting the website of the developer. However, such actions may under certain circumstances affect your secure access to our website or use of services provided by us.

In addition, our website may include some electronic images (referred to as "single-pixel GIF files" or "web beacons"). Through web beacons, a website can help to calculate the number of users visiting the webpage or access some cookies. We will use web beacons to collect data regarding your webpage browsing activities, such as webpage addresses visited by you, the reference pages previously visited by you, your browser environment and your display settings.

If, where applicable, you use any service provided by any third party other than us through our website or platform, to keep your account secure and for safer user experience, we may use a private network protocol and proxy technology (referred to as "private network channel"). With the private network channel, we can help you identify high risk sites that are already known to us and thus reduce risks associated with phishing and account breaches arising from those sites. The private network channel can also better protect the common rights and interests of you and third parties by preventing lawbreakers from tampering with the services expected by you and third parties, including advertisements injection and illegal contents tampering caused by unsecure routers and illegal base stations. Meanwhile, we may obtain and preserve information about your computer, such as IP address, hardware ID and the location of the pages you visited.

VI. How You Can Exercise Your Rights regarding Your Personal Information

We will take appropriate technical measures to ensure that you can access, update and correct your personal information and exercise your other rights to personal information provided under applicable laws and regulations. 请note that if you opt out of certain types of data collection or use, you may not be able to use all features of our services. You may carry out the relevant operations by contacting us via the following email address.

When we cooperate with third party organizations to provide services, to the extent required by applicable laws and regulations, your use of such third party organization's services will be subject to its published privacy policy or other terms and conditions (if any). 请read the relevant policies and terms carefully; if you have any questions, you may consult the third party organization which provides the services you use.

If you have any questions about this Policy or have any complaints or comments on the processing of your personal information, please contact us via the following channels:

Email address: support@openqiao.com

We will respond to you within the timeframe required by applicable laws and regulations. We need to verify your identity and credentials to protect your information security. Depending on your country/region of residence, you may have the right to lodge a complaint with the supervisory authority or initiate legal proceedings in a court of competent jurisdiction.

VII. Statement on User Content

As your service provider, we provide services to you solely based on your instructions. You are solely responsible for your Inputs and the consequences of providing Inputs.

You may provide input into the Services, which may include text, images, data, audio, video, software, database information, plugins/API information and other types of work ("Input") and receive an output from the Services based on your Input ("Output"). You retain copyright and any other proprietary rights that you may hold in the Input.

Collectively, the Input and Output are "User Content", which includes all data you upload while using the service, all data processed by us during providing services, and all data derived from your use of our products or services that you can control and manage. We may store, transfer or train on your anonymized User Content for improving our model.

VIII. Statement on Third Party Liability

请note that the platform on which this Policy is published may contain links to third party websites. These third parties may place their own cookies or pixel tags or otherwise collect and process your personal information that are beyond our control and which may not be subject to this Policy. While we will use commercially reasonable efforts to require these entities to take measures to protect your personal information, we cannot guarantee that these entities will take all the protective measures as requested by us. You are therefore kindly asked to contact these entities directly to understand the details of their privacy policies. If you find that there exists any risk in webpages created by, or applications developed by, these third parties, you are recommended to cease the use of such webpages or applications to protect your legal rights and interests.

IX. No Intention to Collect Personal Information of Minors

Our website is not intended for, and we will not knowingly collect personal information from, minors under the age of majority in your country/region of residence.

X. Application and Revision of the Policy

Unless there is a separate privacy policy for relevant services or there are any special provisions in the relevant users' service agreement, this Policy is applicable to all the services of us.

We may update this Policy in due course upon any significant changes as follows:

(1) changes in our corporate particulars, such as: changes in ownership arising out of any mergers, acquisitions and restructuring;

(2) changes in the scope, purpose, rules and method of collecting, storing and using personal information;

(3) changes in the recipients that may receive personal information, scope, purpose and/or method of disclosing personal information;

(4) changes in the way you access to and manage your personal information;

(5) changes in data security capabilities and information security risks;

(6) changes in the channels and mechanisms for user inquiries and complaints, and in external dispute resolution agencies and the contacts; or

(7) other changes that may have a material effect on your rights and interests in respect of your personal information.

If this Policy is updated, we may notify you by ways of emails/SMS, portal, platform or website message or announcements on our website. In order for you to receive such notifications in a timely manner, it is advisable that you notify us promptly upon any update to your contact information. If you continue to use relevant services after the Policy updates become effective, you are deemed to have fully read, understood and accepted the updated Policy and that you are willing to be bound by such updated Policy.

You may view this Policy on the homepage of our website.

XI. Notes to Key Terms Used in the Policy

1. For the purpose of this Policy, "开桥" or "we", "our" "us" means 开桥 openqiao, the operator of the 开桥's products and services, which is a company incorporated under the laws of Singapore, with its registered place at 11 COLLYER QUAY, #05-06C, THE ARCADE, SINGAPORE 049317.

2. For the purpose of this Policy, "personal information" has the meaning ascribed to the term "personal information", "personal data", "personal identifiable information" or other equivalent term under applicable laws and applications.

3. For the purpose of this Policy, "identifiers" means the information used by us to verify your identity, such as your account login name, password, SMS verification code, telephone number, and mobile number, in each case to the extent necessary and narrowly restricted to achieve the purpose of processing.

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