Effective Date: September 23, 2026

Last Updated: September 23, 2026

Introduction

Lens Technology (Xiangtan) Co., Ltd. (hereinafter referred to as "Lens Technology", "we", "us", or "our") is firmly committed to protecting user privacy and maintaining data security.

This General Privacy Policy applies to all pre-installed system applications, system services, and underlying components integrated within the device operating system (ROM) by Lens Technology for devices primarily distributed in Japan, South Korea, and other international markets (hereinafter collectively referred to as "System Applications"). Whether accessed on the primary screen, operated via the secondary display, or scheduled by background system services, this Policy explains how we collect, use, store, share, and protect your information, as well as the data subject rights available to you. This Policy complies with the Japanese Act on the Protection of Personal Information (APPI), the South Korean Personal Information Protection Act (PIPA), and applicable international standards.

 

1. Scope of Applications and Components Covered (29 Items)

This Policy governs the following 29 pre-installed applications and architectural modules:

Category	Application / Component Name	Functional Description
Communication	Contacts	Browsing, searching, creating, and managing local contacts
	Contacts Data Service	Underlying contact database engine and local storage persistence
	Dialer / Phone	Placing/receiving calls, active call controls, and call history tracking
	SMS & MMS	Text and multimedia message transmission and conversation management
	Telephony Service	Telephony network state maintenance and underlying carrier services
	Cell Broadcast	Emergency alerts, natural disaster warnings, and public safety notices
	SIM Toolkit (STK)	Carrier value-added services and SIM card command interaction
System & UI	System Launcher & Easy Launcher	Home screen arrangement, application drawers, and launch shortcuts
	Sub-Display Interaction Manager	Secondary screen window layout, cover widgets, and touch controls
	System Status & Notification Bar	Quick settings toggles, status icons, and global notification center
	System Settings	Device hardware/software configuration and personal preferences
	Settings Intelligence & Suggestions	Settings search indexing and contextual system suggestions
	Intent Resolver	System share sheets, default application chooser, and intent routing
	Wallpaper Manager	Static and live wallpaper rendering for home and lock screens
Media & Aid	Camera	Photography, video recording, zoom control, and shooting parameters
	Magnifier / Electronic Visual Aid	Real-time optical magnification, vision assistance, and frame freezing
	Sound Recorder	Local voice memo recording, audio playback, and file management
	Sound Picker	Local audio filtering for ringtones, alarms, and notifications
	FM Radio	Local FM radio broadcast tuner and listening utility
Tools & Safety	Pedometer Service	Step calculation and physical activity logging via motion sensors
	Safety Feature / SOS Service	Emergency calls, fall/collision detection, and SOS message transmission
	Clock & Alarm	Alarms, world clock, stopwatch, and timer alerts
	Calculator	Standard arithmetic and scientific calculations
	Offline Log Collector	Local failure dump and anomaly stack trace capture during defects
Core Libraries	Common UI Component Library	Unified design controls and system interface visual guidelines
	Custom System SDK	Hardware interface abstractions and service communication protocols
	Core System Service Package	System utility orchestration and background service coordination
	Framework Extension Services	Low-level Android framework customization and extensions
	AOSP Library Adapter	Operating system low-level runtime compatibility library

 

 2. Terms and Definitions

Personal Information: Any information recorded electronically or otherwise that can be used alone or in combination with other information to identify a specific natural person or reflect personal activities.

Non-Personally Identifiable Information (Non-PII): Technical data that cannot identify a specific individual on its own or in combination with other data, such as anonymous hardware specs, performance metrics, and aggregate usage counters. If Non-PII is combined with Personal Information, the combined set is treated as Personal Information.

Unique Device Identifiers: Non-reversible, hardware-derived identifiers (e.g., OAID) used exclusively for system stability attribution, never linked to real-world personal identities.

 

3. Information We Collect and Purposes of Use (Local-First Principle)   

We adhere strictly to the principles of purpose specification, data minimization, and local-first execution:

3.1 Functional Information by Scenario

Communication (Contacts, Dialer, SMS/MMS, Telephony Service, SIM Toolkit):

Information Processed: Contact names, phone numbers, call records (timestamps, numbers, durations), SMS/MMS text, and timestamps.

【Local-Processing Commitment】: All communication records are stored strictly within local application sandboxes on your device. Unless required by law, we do NOT automatically upload your contacts, call logs, or text messages to remote cloud servers.

UI & Interaction (Launcher, Sub-Display, Status Bar, Wallpaper, Settings, Intent Resolver):

Information Processed: Installed application metadata, home screen grid coordinates, sub-display widget states, and wallpaper/theme preferences.

Purposes: To render icons on both screens, dispatch user touch actions, direct cross-application sharing, and maintain customized desktop layouts.

Media & Accessibility (Camera, Sound Recorder, Magnifier, Sound Picker, FM Radio):

Information Processed: Sensor feeds from cameras, microphone acoustic data, and photo/audio metadata. Purposes: To capture photos, magnify objects for visual assistance, record audio memos, and configure ringtones. Media files reside in local storage.

Safety & Health (Safety Feature / SOS, Pedometer):

Information Processed: Motion sensor readings, configured emergency contacts, and precise location coordinates during an emergency trigger.

Purposes: The pedometer tallies steps locally. The SOS service accesses location strictly upon activation to send distress messages to designated contacts.

3.2 Basic Technical & Diagnostic Information

Device & Environment Attributes: Device model, ROM Build ID, Android OS version, screen resolution, system language, and time zone;

Offline Diagnostic Logs (Offline Log Collector): When an unrecoverable system crash or Application Not Responding (ANR) error occurs, local exception stack traces are captured to assist in defect triage. These logs remain securely isolated locally and are not transmitted online without explicit authorization.

 

4. Legal Basis for Processing Personal Information 

Under applicable data protection frameworks (such as Japan APPI, South Korea PIPA, and international standards), our processing bases include:

1. Contractual Performance: Providing essential operating system utilities and core device services;

2. Explicit Consent: Granted through runtime system permission prompts or in-app toggles;

3. Legal Obligations: Handling emergency public safety alerts ( Cell Broadcast ) and complying with cybersecurity audit regulations; 4. Vital Interests: Processing location and distress information via SOS to protect life and safety in critical situations; 5. Legitimate Interests: Ensuring device network security, improving ROM stability, and protecting against security incidents, with minimal impact on your privacy.

 

5. System Permissions Requested 

Permissions are invoked on demand when corresponding features are utilized:

Category	Permission Types	Applicable Applications	Purpose Description
Contacts	Read / Write Contacts	Contacts, Dialer, Safety Feature	Manage address book and assign emergency contacts
Phone & SMS	Make Calls, Call Logs, Send/Receive SMS	Dialer, SMS, Telephony, Safety Feature	Place phone calls, manage messages, and dispatch SOS alerts
Media Hardware	Camera, Microphone	Camera, Magnifier, Sound Recorder	Capture photos/videos, magnify visuals, and record audio
Storage	Access Images, Videos, Audio, Files	Camera, Sound Recorder, Wallpaper, Sound Picker	Save recordings, read wallpapers, and configure custom tones
Body Sensors	Physical Activity Recognition	Pedometer Service	Query hardware sensors to record daily step counts
App Listing	Query Installed Applications	System Launcher, Sub-Display, Intent Resolver	Discover installed apps to display icons and share sheets
Location	Precise and Approximate Location	Safety Feature / SOS Service	Retrieve coordinates strictly when dispatching emergency alerts
Network	Network Access & Network State	System Settings, Core Services	Verify critical firmware updates and inspect connectivity

 

 

Control: You can inspect or revoke these authorizations at any time via [Settings -> Apps -> Permission Manager].

 

6. Sharing, Entrusted Processing, and Disclosure 

1. No Commercial Sale & Tracking: Lens Technology does not sell or lease your personal data to commercial advertisers or data brokers. The listed System Applications do not embed commercial profiling or ad-tracking SDKs.

2. Entrusted Processing: If diagnostic dump analysis is outsourced to specialized technical partners, we enter into strict Data Processing Agreements (DPAs) requiring them to process de-identified logs strictly in accordance with our instructions. 3. Statutory Disclosure: We disclose data only where required by applicable laws, formal judicial orders, or binding regulatory mandates in Japan, South Korea, or other competent jurisdictions.

 

7. Data Storage, Security, and Retention 

1. Storage Location: Operational data resides strictly in local device storage. Diagnostic logs extracted during authorized repairs are maintained on secure servers.

2. Retention Rules:

Personal data (contacts, SMS, photos) is retained until you delete it, factory-reset the device, or wipe application data; Offline crash logs overwrite automatically once buffer limits are met, retained for no longer than 180 days. 3. Security Measures: We enforce Android sandbox isolation, SELinux policies, and file-based encryption (FBE) to prevent unauthorized cross-application data access.

 

8. Global Transfer of Personal Information (Cross-Border Transfers) 

Because this device is marketed primarily in Japan and South Korea, your operational data resides locally on your device and does not involve cross-border transfers under normal circumstances.

If you apply for customer support or maintenance in Japan or South Korea and explicitly agree to export diagnostic dumps for fault analysis, such de-identified technical logs may be transferred to Lens Technology's technical support center in China. In such events, we will strictly observe the statutory requirements of the Japanese APPI and Article 28-8 of the South Korean PIPA, implementing equivalent encryption, contractual safeguards, and access controls.

 

9. Your Rights and Controls 

Subject to APPI and PIPA, you retain full control over your personal data:

Access, Correction & Deletion: Manage data within each application; navigate to [Settings -> Apps -> Select App -> Storage] and tap "Clear Storage" to delete local configuration and cache files permanently;

Permission Revocation & Disabling: Turn off permissions anytime in Settings. Non-essential applications (e.g., Calculator, FM Radio, Sound Recorder) can be disabled via their app settings screen, terminating background execution; Lodging Complaints: If you have questions or wish to exercise statutory rights, you may submit an inquiry to our Data Protection Officer using the contact details below.

 

10. Protection of Minors 

We place high importance on protecting children's privacy. These System Applications provide general-purpose OS functionalities and do not profile or target children under the age of 14. Minors should use this device and its system applications under the supervision and consent of a parent or legal guardian.

 

11. Updates & Contact Us 

We may revise this General Privacy Policy from time to time. Significant modifications will be announced through system update release notes (Changelog) or within the "About" screen of the applications.

 

If you have questions, feedback, or complaints regarding this Privacy Policy, please contact our dedicated Data Protection Officer: 

Entity:  Lens Technology Co., Ltd.

Designated Email: Stone.Wu@hnlens.com

Address: Liuyang Biomedical Park, Liuyang City, Changsha City, Hunan Province, China