PomeloX Terms of Service & Privacy Policy (Combined Version)

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Part I: Terms of Service

Article 1 (Definitions)

• 1.1 "Platform/We" refers to "PomeloX" and its operating entities.
• 1.2 "User/You" refers to natural persons who register or use platform services (including guardian representation, school-verified student users, etc.).
• 1.3 "Services" refers to functions and activities provided online or offline by the platform, including AI Q&A, Wellbeing Plan, airport pickup & transportation, activity management, volunteer management, local discounts, marketplace/job matching, alumni network, etc.
• 1.4 "Third-party Service Providers" refers to external partners such as carriers, merchants, payment institutions, cloud services, communication services, volunteer organizations, etc.
• 1.5 "Applicable Law" refers to laws, regulations, and mandatory policies that are binding on users' locations and platform entities (including Chinese mainland law, US federal law, and state laws, etc.).

Article 2 (Service Scope and Nature)

2.1 The platform is an information and collaborative service provider and does not directly provide police, medical, and public safety services. In case of emergency danger, please prioritize contacting local emergency numbers (110/120/911).

2.2 Specific functions:

• AI Q&A: Provide study abroad guides, visa/course/housing information suggestions (for reference only, not legal/immigration/medical advice)
• Wellbeing Plan: Missing person emergency coordination, volunteer clue collection and liaison (no guarantee of recovery or specific results)
• Airport Pickup & Transportation: Free bus reservations, paid pickup/rideshare (provided by third-party carriers/drivers)
• Activity Management: Event publishing, registration management, check-in/check-out and QR code verification
• Volunteer Management: Check-in/out, hour tracking and certification (non-employment/labor relationship)
• Local Discounts: Merchant offers, points and redemption (subject to merchant rules)
• Marketplace/Job Matching: Information posting and chat matching (platform does not participate in transactions or provide guarantees)
• Alumni Network: Email verification, trusted referrals (does not constitute employment commitment)

Article 3 (Registration and Eligibility)

• 3.1 You must be at least 14 years old to register independently; those under 14 must have guardian representation or provide explicit guardian consent (US law has additional restrictions for those under 13 under COPPA).
• 3.2 You should provide truthful, accurate, and complete registration information and keep it updated; hold a valid school email or referral code (if applicable).
• 3.3 You should properly safeguard your account and password and be responsible for all activities under your account. If you discover unusual use/security risks, you should immediately notify the platform.

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Part II: Privacy Policy

Article 1 (General Provisions and Scope)

• 1.1 This policy applies to your use of all platform functions. We may act as "personal information processor/controller" or "service provider/processor" and share or entrust processing with third-party service providers within the minimum necessary scope.
• 1.2 We follow the principles of legality, legitimacy, necessity, good faith, and transparency, minimize the processing of sensitive personal information, and implement differentiated protection.

Article 2 (Information We Collect)

2.1 Categories of Information Collected:

Personal Information You Provide:

• Registration Information: Legal name, English nickname, affiliated school, school email
• Contact Information: Chinese or US phone number
• Identity Verification: Referral code information, SMS verification codes
• Activity-Related: Activity registration information, personal preference settings
• Volunteer Service: Volunteer activity participation records, check-in times

📱 SMS Service Terms

Information We Collect Automatically:

• Device Information: Device model, operating system version, application version
• Usage Data: Application usage statistics, feature click records
• Network Information: IP addresses (used only for technical support and security protection)
• Push Information: Device push tokens (used for sending notifications)

Article 3 (How We Use Your Information)

We collect your personal information solely for the following lawful purposes:

With Your Consent:

• Account creation and management
• AI Q&A services
• Activity notifications and reminders

For Contract Performance:

• Activity registration and volunteer management
• Airport pickup and transportation services
• Local discount services

For Legitimate Interests:

• Service improvement and user experience
• Fraud prevention and security
• Technical support and maintenance

Article 4 (Third-Party Service Integration)

To provide comprehensive services, we integrate the following third-party services:

• Gmail SMTP: Email delivery and notifications
• Cloudflare R2: Secure storage of activity images and user avatars
• Firebase FCM: Push notifications and activity reminders
• Google OAuth: Optional third-party login method

These service providers adhere to strict data protection standards, and we do not provide them with personal information beyond what is necessary for service delivery.

Article 5 (Information Sharing)

We only share your personal information in the following circumstances:

• With your explicit consent
• As necessary to fulfill contracts
• To protect your or others' significant legitimate interests
• As required by applicable laws and regulations

We do not sell your personal information to third parties.

Article 6 (Your Privacy Rights)

Under applicable privacy laws, you have the following rights:

• Right to Know: What personal information we collect and how we use it
• Access Right: Request copies of your personal information
• Right to Correct: Correct inaccurate personal information
• Right to Delete: Request deletion of personal information
• Right to Restrict: Limit how we process your personal information
• Right to Data Portability: Obtain your personal information in a structured format
• Right to Withdraw Consent: Withdraw consent for personal information processing

To exercise your rights: Email us at info@pomelo-x.com or contact us through the app.

Article 7 (Cross-border Data Transfer)

To provide our services, your personal information may be transferred to our overseas collaborative partner Vita Global (USA) for the following purposes:

• Service delivery and customer/technical support
• Data backup and security
• System maintenance and technical support

We will take appropriate protective measures in accordance with the Personal Information Protection Law and other regulations, including signing standard contractual clauses and conducting security assessments.

Article 8 (Children's Privacy Protection)

• Under 14: Must obtain explicit parental consent
• 14-18 years old: Appropriate protection provided, parental guidance recommended
• 18 and above: Can independently use all functions

We implement stricter security measures and data protection for minors' information.

Article 9 (Data Security Measures)

Technical Safeguards:

• AES-256 encryption for sensitive data protection
• HTTPS encrypted transmission across the platform
• Strict access controls and identity verification
• 24/7 security monitoring and anomaly detection

Operational Safeguards:

• Employee access limited to work-necessary data only
• Logging of all data access and operations
• Regular security risk assessments
• Security incident response procedures

Article 10 (Data Storage)

• Storage Location: Primarily stored on servers within China
• Retention Period: Only for the minimum time necessary to achieve processing purposes
• Deletion Mechanism: Automatic deletion or anonymization after expiration

Article 11 (Policy Updates)

We may modify this policy based on legal changes or business development. Important updates will be communicated through:

• Website announcements
• In-app notifications
• Email notifications

Material changes will require your consent.

Contact Us

For privacy-related questions, please contact:

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PomeloX Terms of Service & Privacy Policy
Version v1.2 | Effective Date: May 21, 2026
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