Effective date: 2025-12-27

Welcome to the Volthub app (hereinafter referred to as "this App") provided by XD-FINANCE. We respect and protect the personal privacy of all users of this App. To provide you with better services, this App collects, uses, stores, and shares your personal information in accordance with the terms of this Privacy Agreement. We aim to clearly explain how we handle your personal information through this Agreement. We recommend that you carefully read and understand this Agreement before using the App. By choosing to use this App, you acknowledge and accept all the terms of this Agreement.

I. Information we collect

When you use this app, we may collect and use the following information about you:

1. Account Information:
When you register and create a Volthub account, you may need to provide an email address and phone number. We will verify your identity by sending a verification code to ensure account security. You can choose to set a username and password, or log in to this app using a third-party account (if applicable and supported in Ghana, such as Google account). If you log in with a third-party account, we will collect publicly available basic information from that platform (e.g., username, profile picture, etc.), subject to the platform's terms of service.
2. Device Information:
When using this app, we automatically collect device-related information, including but not limited to: device model, device identifiers (e.g., IMEI, Android ID, OAID, MAC address), operating system version, network type, IP address, device sensor data (e.g., accelerometer, gyroscope – used solely for app functionality like landscape-to-portrait switching optimization), and approximate location information (region determined by IP address). This data helps us identify your device, ensure app stability, troubleshoot issues, optimize performance and user experience, and provide content recommendations tailored to your location.
3. Behavioral Data Usage:
We collect behavioral data from your app usage, including short drama content you browse, click, play, save, share, comment on, or search for, viewing duration, likes or other interactions, search keywords, as well as your app usage frequency, time, and duration. This data helps analyze your usage patterns and preferences to personalize recommendations of short drama content you may enjoy, improve our products and services, and enhance user experience.
4. Content Notice:
When you upload, publish, or share your original short-form content (if available), we collect the content itself, along with any embedded text, images, audio, video, and metadata such as descriptions and tags you provide. Please ensure your content does not infringe on third-party rights and complies with applicable laws, regulations, and the app's terms of service. We collect this information to display your content and enable sharing and interaction with other users.
5. Transaction Information (if applicable):
If this app offers future paid services or virtual item purchases, we will collect your transaction details including amount, time, and order number when processing transactions. We do not directly collect sensitive payment information such as bank card numbers or passwords. These details will be handled by your selected third-party payment service provider (e.g., Ghana's local payment channels or international payment platforms). We will obtain necessary transaction result information as per agreements with third-party payment service providers to complete transaction confirmation and subsequent services.
6. Feedback:
When you contact us through the customer service feature, feedback, or other methods of this app, we collect your contact information (such as your email or phone number) along with your feedback, problem description, and related screenshots. This information helps us process your inquiries, complaints, or suggestions and resolve any issues you encounter.
7. Use of Device Permissions:
To provide certain core features, this App may request specific system permissions on your device. For example: (1) Camera: used only when you voluntarily use in-app features that require taking photos, recording video, or scanning codes (if available). We do not access your camera in the background and do not collect images or video for purposes unrelated to these functions. (2) Microphone: used only when you actively use features that require audio input (such as recording voice content, if available). We do not listen to or record your audio without your clear operation. (3) Photos/Media/Files or Storage: used to read and write necessary resources such as video cache files, cover images, and application configuration so that videos can play smoothly and your basic preferences can be saved. We do not access unrelated files stored on your device. (4) Location (approximate location derived from network or device information): used to provide content recommendations, advertising (if any), and service optimization suitable for your region, and to meet compliance requirements in different regions. We do not use it to continuously track your movements with precise real-time positioning. You may refuse or withdraw the above permissions at any time through your device settings, but some features of this App that rely on the corresponding permission may become unavailable after you withdraw the permission.
2. How We Use Your Information

We collect your information primarily for the following purposes:

1.
Provide and maintain services: Ensure the application runs smoothly and offer core features such as account management, content browsing and playback, and interactive social features (e.g., comments and sharing).
2.
Personalized recommendations: Based on your device information, usage behavior, and preferences, we recommend short dramas, ads (if any), and other relevant content you might enjoy, helping you discover quality content more easily.
3.
Enhance products and services: By analyzing collected information to understand user needs and usage habits, we can continuously optimize and improve this application, develop new features and services, fix potential vulnerabilities and defects, and enhance the application's stability, security, and user experience.
4.
Security and Fraud Prevention: Use collected information to identify and verify user identities, detect and prevent security risks, fraudulent activities, illegal activities, and violations of the app's user agreement or privacy policy. This protects your and other users' account security and legal rights, and maintains the app's normal operation.
5.
Customer Support: When you need help, we will contact you using the information you provided (such as contact details and problem description) to effectively respond to your inquiries and requests, and resolve any issues you encounter during use.
6.
Compliance requirements: Adhere to relevant laws and regulations, comply with legal requirements or regulatory authorities, cooperate with investigations and evidence collection, and fulfill statutory obligations.
7.
Other purposes with your consent: With your explicit consent, we may use your information for other specific purposes.
3. How We Share Your Information

We highly value the security of your personal information and will not sell, rent, or lend your personal information to any third party. We may share your information only under the following circumstances:

1. Obtain your explicit consent:
With your explicit authorization, we will share your personal information with designated third parties in the manner and scope you agree to.
2. Service Providers:
To deliver and maintain this application's services, we may collaborate with third-party service providers, including but not limited to cloud service providers, data analytics service providers, content delivery network (CDN) service providers, payment processors (where applicable), customer support service providers, and advertising service providers (where applicable). We will only provide these third parties with information necessary to fulfill their services, and through contractual agreements, we strictly require them to process your information in accordance with our instructions, exclusively for service purposes. They must not use the information for any unauthorized purposes and are required to implement appropriate security measures to protect your information.
3. Legal Requirements or Protection of Legitimate Rights:
When necessary to comply with applicable laws, legal procedures, government mandates, or judicial rulings, or to protect the legitimate rights of us, our users, or the public from harm, we may disclose your personal information as required by law. This includes, but is not limited to, identifying, contacting, or taking legal action to prevent, restrict, or pursue fraud, potential threats to personal safety, or violations of our service terms.
4. Business Mergers, Acquisitions, or Asset Transfers:
Should we undergo mergers, acquisitions, asset restructuring, bankruptcy liquidation, or other transactions involving asset or business transfers, your personal information may be transferred to third parties as part of the transferred assets. In such cases, we will require the transferee to continue complying with the provisions of this Privacy Agreement to safeguard your personal information security. Should any material changes occur to the personal information processing terms in this Privacy Agreement, we will notify you through appropriate channels and, upon obtaining your consent (as required by applicable laws), the transferee will continue processing your information.
4. How We Protect Your Information

We have implemented a series of reasonable technical and management measures to protect your personal information security, preventing loss, misuse, unauthorized access, disclosure, tampering, or damage.

1. Security Measures:
We use encryption technologies (e.g., SSL/TLS) to protect your personal information during transmission. For data stored on our servers, we implement strict access controls and encrypted storage. We regularly update our security technologies to address evolving threats.
2. Security measures:
We have established a comprehensive information security management system and operational procedures, conducting rigorous background checks, security training, and permission management for employees handling user information. We restrict employees' access scope to user information and monitor and audit the information processing process.
3. Security Incident Response:
We have established a contingency plan for security incidents. In the event of a personal information security incident, we will immediately activate the plan, take remedial actions, and promptly report to you and regulatory authorities in compliance with applicable laws and regulations.
4. User self-protection:
Protect your account information and password security. Do not disclose them to others. If you detect any security risks, contact us immediately through the app's customer service channel.

Despite implementing the aforementioned security measures, we cannot guarantee absolute information security in the digital environment. Therefore, we cannot fully ensure that your personal information will remain completely protected from unauthorized access, use, or disclosure under any circumstances. Should your information be compromised, lost, or damaged due to force majeure or circumstances beyond our control, we will endeavor to take remedial actions but will not assume liability for such incidents.

V. Your Rights

You have the following rights to your personal information:

1. Access and Review:
You have the right to access and review your personal information in this app, such as your account details (username, phone number, etc.), favorites, and viewing history. You can check them through the "Settings" or relevant features in the app.
2. Correction and Supplement:
If you find any errors or incomplete information in your personal details, you have the right to request corrections or supplements from us. You can modify certain editable information through the account settings in the app, or contact us via customer service for corrections.
3. Right to Erase:
You have the right to request us to delete your personal information under the following circumstances:
o Our collection and use of your personal information violate legal regulations or the terms agreed upon by both parties.
o We have processed your personal information beyond the agreed scope.
o You no longer use this app and request to sign out.
o We are discontinuing this app service.

You can submit a deletion request through customer service. We will verify your identity and process your request as soon as possible in compliance with legal requirements. Note that deleting certain information may affect some features of this app.

4. Withdrawal of Consent:
You may withdraw your consent to our collection and use of personal information at any time. For example, you can disable location, camera, microphone, and other permissions in your device settings. Please note that after withdrawing consent, we will no longer process the corresponding personal information based on that consent. However, this does not affect any information processing we performed based on your consent prior to withdrawal, and may result in some features of this application that rely on such information becoming unavailable.
5. Account Cancellation Policy:
You have the right to cancel your Volthub account. You may submit a cancellation request through the app's "Settings> Account Security> Cancel Account" (or similar navigation path), or contact our customer service for assistance. Before proceeding, please note the following consequences: Once canceled, the account will be permanently non-recoverable. You will no longer be able to log in or use the app, and all account data (including but not limited to personal information, viewing history, favorites, points, etc.) will be deleted or anonymized (unless otherwise required by applicable laws and regulations). After submitting your request, we will complete the cancellation process within a reasonable timeframe, provided we verify your identity and confirm there are no outstanding transactions (if any).

To safeguard your account security and personal data rights, we may require identity verification when processing your requests. We will respond within a reasonable timeframe after successful verification. Requests that are baseless, involve excessive technical complexity (e.g., developing new systems or fundamentally altering existing practices), may compromise third-party privacy, or violate legal regulations will be declined with clear justification provided.

VI. Information Storage and Retention
1. Storage location:
Your personal information collected by us will be stored on our servers. We strictly comply with relevant laws and regulations and take appropriate security measures to protect your personal information.
2. Storage Period:
We will retain your personal information for the duration necessary to fulfill the purposes specified in this Privacy Agreement, unless otherwise required by applicable laws or regulations. After this period, we will delete or anonymize your personal information. Specifically:
o Account information: We will retain your account information while your account is active. After you log out, we will delete or anonymize your account information, unless otherwise required by law.
o Behavioral and device information: We will retain this information for as long as necessary to fulfill the collection purpose, typically one year after your last use of the app, or longer as required by law.
o Content information: If you upload or publish content, we will retain it for as long as your account exists. After you cancel your account, the content will be deleted or anonymized unless required by law or necessary to fulfill legal obligations.
o Transaction information (if applicable): We will retain your transaction information until the transaction is completed, in compliance with applicable laws and regulations regarding the retention of transaction records (typically 5 years or longer as required by law).
o Feedback: We will retain your feedback for a reasonable period necessary to resolve the issue or achieve the intended purpose.
7. Third-party Links and Services

This application may contain links to third-party websites, apps, or services (e.g., external links in short-form content or links shared via this app to third-party social platforms). These third parties have their own privacy policies and terms of service, and their data handling practices are not governed by this Privacy Agreement. We assume no responsibility for their privacy practices. We recommend that you carefully review and understand their privacy policies before accessing these third-party links or using their services.

Additionally, this application may integrate third-party SDKs (Software Development Kits) to enable specific features such as statistical analysis, ad delivery (if applicable), third-party login, payment processing (if applicable), and sharing functions. These third-party SDKs may collect and process certain information about you in accordance with their respective privacy policies. We conduct rigorous security assessments of the integrated third-party SDKs and require them to handle user information in compliance with the principles of legality, propriety, and necessity.

VIII. Protection of Minors

We place high priority on safeguarding minors' personal information. This application is not intended for minors under 13 years of age. If you are a minor under 13, please do not register an account or use the services of this application. Should we discover that we have collected personal information of minors under 13 without obtaining parental consent, we will immediately delete such information. If you are a guardian and find that your child has provided personal information to us while using this application, please contact us immediately through the contact details provided in Article 10 of this agreement. We will take appropriate measures to protect the minors' personal information.

For minors aged 13 years or older but under 18 years, prior consent from their legal guardians is required before using this application. Guardians have the right to review and request corrections or deletion of their wards' personal information.

IX. Changes to Privacy Agreement

We may update this Privacy Policy from time to time. When significant changes occur, we will publish the updated Privacy Policy in prominent locations within the app (e.g., startup screen, settings pop-up) and notify you via push notifications, email, or other appropriate methods to ensure timely awareness of the changes. The revised Privacy Policy will take effect on the effective date specified in the notification. We encourage you to review this Privacy Policy regularly. If you disagree with the revised Privacy Policy, you have the right to stop using the app. By continuing to use the app after the changes take effect, you acknowledge that you have read, understood, and agreed to be bound by the revised Privacy Policy.

"Significant changes" include, but are not limited to: major alterations in the scope, purpose, or methods of our collection, use, storage, or sharing of personal information; changes in the entity responsible for processing personal information; significant modifications to the manner in which you exercise your personal information rights; or major adjustments to our information security measures.

10. Contact Us

If you have any questions, comments, suggestions, or wish to exercise your personal information rights, or report any violations of this Privacy Agreement, please contact us through the following methods:

Email: jambobo@beelinkafrica.com
In-app customer service: Open the Volthub app, go to "Me-Settings-Help and Feedback" (or similar path)

We will verify and process your request within 15 working days after receiving it, and provide you with the result based on the situation.

XD DIGITAL LTD is highly committed to protecting your personal data in compliance with standard data protection regulations. We only collect basic information necessary to fulfill your physical orders (Name, Shipping Address, Phone Number, Email).

Payment Data Security (PCI-DSS): Volthub DOES NOT collect, store, or process your full credit/debit card numbers, PINs, or CVV codes. All payment processing is securely handled entirely by our PCI-DSS compliant payment gateway provider (Paystack).

Third-Party Sharing: We only share your delivery address with our verified logistics partners to deliver your goods. We will never sell your personal data.

Thank you for reading and understanding this Privacy Policy.