Effective Date: March 23, 2026
"Lumidex Distributor Platform" (hereinafter referred to as "the Platform") is legally owned and operated by Poligon Pte.Ltd. (hereinafter referred to as "the Company" or "us", "we"). We understand the importance of personal information to you, and your trust is very important to us. We will process your personal information in accordance with the provisions of laws and regulations. We have formulated this "Privacy Policy" and specifically remind you to carefully read and understand this Privacy Policy before using the Platform and related services in order to make appropriate choices.
This Privacy Policy will help you understand:
We will collect and use your information in accordance with the Privacy Policy, but will not adopt a mandatory bundled approach to collect personal information in one go solely because you have agreed to this Privacy Policy.
When you use or enable relevant functions or services, we will collect and use relevant information as necessary to implement the functions and services. Unless it is necessary information required to implement business functions or as required by laws and regulations, you may refuse to provide it without affecting other functions or services. We will explain the information to be collected item by item in the Privacy Policy.
To fulfill business functions or as required by laws and regulations, we will collect your personal information when you use specific functions or services.
This Privacy Policy applies to the products and services provided to you in the form of web pages, the Platforms, software development kits (SDKs) and application programming interfaces (APIs) for use by third-party websites and applications, as well as innovative forms emerging with technological development. If you use a particular service or services provided to you by us or our affiliated companies, and there is a separate privacy policy for such services, the corresponding privacy policy shall apply to the relevant service or product; if no separate privacy policy is established, this policy shall also apply to such products or services.
The following text will help you understand in detail how we collect, use, store, transfer (if applicable), and protect personal information; it will also help you understand how to access, copy, correct, delete, and withdraw authorization for personal information. This policy is closely related to your use of our services, and we recommend that you carefully read and understand all the content of this policy to make what you consider appropriate choices. The important content of the terms regarding your rights and interests in personal information has been highlighted in bold; please pay special attention.
1. How we Collect and Use Personal Information
2. Use of Cookies and Similar Technologies
3. Third Parties Involved in Data Processing and Transfer and Public Disclosure of Personal Information
4. How we Store Personal Information
5. How we protect the security of personal information
6. Managing your Personal Information
7. Minimum Age and Minors
8. Privacy Policy Revisions and Notifications
9. Contact Us
We will collect information that you actively provide when using the service, as well as information generated during your use of functions or receipt of services collected through automated means, in the following manner:
1.1 Registration, Login, Authentication, and Retrieval
1.1.1 Registration, Login
a. When you register, log in to the Platform and related services, you can create an account via mobile phone number, email, etc., or log in to the platform using a third-party account that we actually allow for platform login at that time, and complete relevant online identity identification information (avatar, nickname). Collecting this information is to help you complete registration. This platform is only available to distributors who have completed contract signing. If you have not completed online/offline signing, you will not be able to use the platform smoothly. After you register and log in to your account, you can fill in your personal information (name, nickname, etc.), and we will collect the personal information you actively fill in for platform management.
1.1.2 Certification
When you use the identity authentication function or related services, in accordance with relevant laws and regulations, we may collect information about you including but not limited to real identity information (real name, phone number, email address, etc. ), and may also include information related to enterprise qualifications (such as company contact email address, legal person information authentication, etc.) to complete enterprise qualification certification. The above information we collect may be subject to manual moderation through the platform to ensure the authenticity of the information and better facilitate signing contracts and cooperation between both parties.
1.2 Distributor Signing and Management
After you register and log in to the Platform, you can use distributor services through this platform, including but not limited to completing the signing of distribution service agreements, distribution data inquiries, and other services provided by this platform at that time. We will also manage distributors through this platform.
We may provide you with signing services through the capabilities of our partnered third-party e-signature providers. When you use the identity verification function or related services in the e-signature scenario, you may need to complete real-name verification to verify your identity in accordance with relevant laws, regulations, and security requirements. During the real-name verification process, the authentication service providers we partner with may need to use your real name, email address, mobile phone number, etc for identity verification purposes. This information is only used for real-name verification and purposes stipulated by laws and regulations, and will not be used for other purposes without your explicit authorization. Such personal information (including sensitive personal information) collected by authentication service providers will be processed in accordance with their privacy policies.
1.3 Operation and Safety Operation/Guarantee
1.3.1 Operation and Safety Assurance
We are committed to providing you with a secure and trustworthy product and usage environment. Providing high-quality and reliable services and information is our core objective. To maintain the normal operation of our services and protect the legitimate interests of you, other users, or the public from losses, we will collect necessary information for maintaining the safe and stable operation of our products or services.
1.3.2 Device Information and Log Information
a. To ensure the secure operation, quality, and efficiency of software and services, we will collect your hardware model, operating system version number, device identifier, network device hardware address (MAC address), IP address, software version number, network access method, type, status, network quality data, operations, usage, and service logs.
b. To prevent malicious programs, ensure operational quality and efficiency, we will collect application information such as application version, language, country/region, and package name.
c. We may use your account information, device information, service log information, as well as information provided by our affiliates and partners upon obtaining your authorization or as permitted by law, to assess account and transaction security, conduct identity verification, identify illegal and irregular activities, detect and prevent security incidents, and take necessary recording, analysis, and handling measures in accordance with the law.
1.4 Changes to the Purpose of Collecting and Using Personal Information
Please note that as our business develops, we may make adjustments and changes to the functions and services provided by the Platform. In principle, when new functions or services are related to the functions and services we currently provide, the personal information collected and used will have a direct or reasonable connection with the original processing purpose. In scenarios where there is no direct or reasonable connection with the original processing purpose, when we collect and use your personal information, we will separately inform you and obtain your consent again in accordance with the requirements of laws, regulations, and national standards through page prompts, interactive processes, and agreement confirmation.
1.5 Exceptions to Obtaining Authorization and Consent
Please understand that in the following circumstances, in accordance with laws, regulations, and relevant national standards, our collection and use of your personal information do not require prior authorization and consent from you:
a. Related to our fulfillment of obligations stipulated by laws and regulations;
b. Directly related to national security or national defense security;
c. Directly related to public safety, public health, or major public interests;
d. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
e. When it is necessary to safeguard your or others' major legitimate rights and interests such as life and property, but it is difficult to obtain the individual's authorization and consent;
f. Personal information that you have publicly disclosed to the general public on your own initiative;
g. Necessary for signing and performing contracts as required by the personal information subject;
h. Your personal information collected from legally publicly disclosed information, such as through channels like legal news reports and government information disclosure;
i. Necessary for maintaining the secure and stable operation of software and related services, such as detecting and handling faults in software and related services;
j. Necessary for conducting legitimate news reporting;
k. When it is a scientific research institution, necessary for conducting statistics or academic research in the public interest, and when providing academic research results or descriptions externally, de-identifies the personal information contained in the results;
l. Other circumstances stipulated by laws and regulations.
We would like to specifically remind you that if information cannot be used alone or in combination with other information to identify your personal identity, it does not fall within the scope of your personal information in the legal sense; when your information can be used alone or in combination with other information to identify your personal identity, or when we combine data that cannot be linked to any specific personal information with other personal information of yours, during the period of combined use, such information will be treated and protected as your personal information in accordance with this Privacy Policy.
1.6 Google API Service Limited Use
Our use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
1.7 YouTube API Services and YouTube User Data
The Platform uses YouTube API Services to provide authorized channel analytics, comment management, and video upload functions. By using these functions, you also agree to be bound by the YouTube Terms of Service. Google's processing of information is governed by the Google Privacy Policy. You must agree to this Privacy Policy before using the Platform's YouTube API-enabled functions.
1.7.1 YouTube Data We Access, Collect, and Store
With your authorization, we may access, collect, process, and store the following information to the extent necessary for the functions you choose to use:
a. Google OAuth access tokens, refresh tokens, authorization status, granted scopes, and related technical identifiers;
b. YouTube account, channel information, including channel IDs, channel names, and authorization status;
c. YouTube video information, including video IDs, titles, descriptions, thumbnails, visibility settings, publishing status, and other metadata;
d. YouTube Analytics and Reporting data for your authorized content, including viewing performance, estimated revenue, advertising revenue, ad performance, and related reporting dimensions;
e. YouTube comment information, including comment and reply text, comment IDs, the relevant video and channel, comment author channel information, moderation status, and reply status; and
f. Video files and metadata that you select from the Platform's content library for upload to YouTube, the YouTube channel and visibility setting selected for the upload, the resulting YouTube video ID, the association between that ID and the corresponding content in the Platform.
1.7.2 How We Use YouTube Data
We use the above information only to provide and maintain the YouTube-related functions that you authorize, including:
a. retrieving and displaying channel- and video-level analytics, estimated revenue, and advertising performance for channels that you have authorized;
b. displaying comments and enabling automated or manual replies on behalf of an authorized channel in accordance with reply rules and settings specifically enabled by you;
c. uploading videos selected by you from the Platform's content library to the YouTube channel you select, applying the title, description, visibility, and other metadata confirmed by you, and maintaining the association between the Platform content and the resulting YouTube video.
We do not use YouTube Authorized Data for undisclosed secondary purposes. If we introduce a new purpose or materially change how YouTube API Data is accessed, collected, or used, we will update this Privacy Policy and obtain your consent again before applying the new processing to your data.
1.7.3 Authorized Actions and User Control
The Platform will identify the YouTube channel associated with an authorized request. Actions that publish or modify content on YouTube, including posting comment replies and uploading videos, will be performed only after you have specifically enabled or confirmed the relevant action, rule, or task. You can review or configure, as applicable, the target channel, reply settings, video title, video description, and video visibility. For video uploads, you can choose whether the video will be public, private, or unlisted.
1.7.4 Disclosure and Access
YouTube Authorized Data will only be made available to the authorizing user and persons or agents expressly authorized by that user. We may disclose such data to Google and YouTube as necessary to operate the requested functions, to our affiliates and authorized personnel who need it to provide or secure the Platform, and to service providers processing the data on our behalf under confidentiality and data protection obligations. We do not sell YouTube Authorized Data or permit service providers to use it for their own independent purposes.
We keep data for different YouTube content owners logically separated and do not combine data from different content owners to generate insights into YouTube's usage, revenue, or other aspects of YouTube's business.
1.7.5 Storage, Refresh, and Security
We retain Google OAuth tokens only for as long as necessary to provide the functions covered by your active authorization. YouTube Analytics API and YouTube Reporting API data may be retained for as long as necessary for the authorized reporting purpose, provided that we verify at least once every 30 calendar days that the authorization remains valid. Other YouTube Authorized Data will be deleted or refreshed no later than 30 calendar days after it was obtained, unless a longer period is permitted by YouTube's policies and remains necessary for the purpose specifically authorized by you. We use administrative, organizational, and technical safeguards, including access controls and industry-standard transport encryption, to protect YouTube API Data against unauthorized access, use, or disclosure.
1.7.6 Revoking Authorization and Deleting YouTube Data
You may request that we disconnect your YouTube account and delete YouTube data stored by the Platform by contacting Lumidex@bytedance.com. You may also revoke the Platform's access directly through the Google Security Settings page.
1.8 Email Notification
You acknowledge and agree that, regarding your contact information (e.g., email address) provided during your use of the product and/or service, we may send various types of notifications to one or more of them for purposes such as user identity verification and security verification in our operations.
Similar technologies such as cookies and device information identification are commonly used technologies in the Internet. When you use the Platform and related services, we may use related technologies to send one or more cookies or anonymous identifiers to your device to collect, identify, and store information when you access and use this product. We promise not to use cookies for any other purpose than those described in this Privacy Policy. We use cookies and similar technologies mainly to achieve the following functions or services:
2.1 Ensure the secure and efficient operation of products and services
We may set cookies or anonymous identifiers for authentication and security purposes to confirm whether you are securely logged into the service or have encountered theft, fraud, and other illegal activities. These technologies will also help us improve service efficiency and enhance login and response speed.
2.2 Helps you enjoy a more convenient access experience
Using such technologies can help you eliminate the steps and processes of repeatedly filling in personal information and entering search content (example: recording searches, form filling).
3.1 Partners Involved in the Data Usage Process
3.1.1 Principles
a. Legality Principle: When engaging in data usage activities during cooperation with partners, there must be a legitimate purpose and compliance with the legal basis for legitimacy. If the partner's use of information no longer complies with the legality principle, it should no longer use your personal information, or resume use after obtaining the corresponding legal basis.
b. Principle of Justification and Minimum Necessity: Data usage must have a legitimate purpose and be limited to what is necessary to achieve that purpose.
c. Principle of Security and Prudence: We will carefully assess the purposes for which our partners use data, conduct comprehensive evaluations of their security capabilities, and require them to comply with the cooperation legal agreements. We will conduct strict security monitoring on the software development kits (SDKs) and application programming interfaces (APIs) through which partners access information to protect data security.
3.1.2 Entrusted Handling
In scenarios where personal information is entrusted for processing, we will sign relevant processing agreements with the entrusted cooperation partners in accordance with legal requirements and supervise their personal information usage activities.
3.1.3 Joint Processing
In scenarios where personal information is jointly processed, we will sign relevant agreements with our partners in accordance with legal requirements and stipulate our respective rights and obligations to ensure compliance with relevant legal provisions and protection of data security during the use of relevant personal information.
3.1.4 Scope of Partners
If the specific functions and scenarios involve services provided by our affiliates or third parties, the scope of partners includes our affiliates and third parties.
3.1.5 Data Usage for Implementing Functions or Services
a. Identity Verification: When you use identity verification features or related services, you may need to complete real-name authentication to verify your identity in accordance with relevant laws, regulations, and security requirements. During the real-name authentication process, the authentication service providers we cooperate with need to use your real name, email address, ID number, mobile phone number, and other information. Some of this information is personal information. Refusing the above use will prevent you from completing identity verification but will not affect the normal use of other functions of the Platform. This information is only used for real-name authentication and purposes stipulated by laws and regulations, and will not be used for other purposes without your explicit authorization.
b. Settlement Function (if applicable): The payment services involved in the settlement function are provided to you by us or third-party payment institutions cooperating with us. During the settlement process, we or third-party payment institutions cooperating with us will use your name, bank card type and card number, expiration date, and mobile phone number to provide the function. The collection of such personal information are necessary for the settlement function. Refusing the above use will result in your inability to use this function, but will not affect the use of other functions.
c. To enable the Model Adaptability message sending function of the terminal you are using, terminal device manufacturers (such as Huawei, Xiaomi, Meizu, etc.) may use your phone model, version, and related device information through technologies such as SDK.
d. Customer Service: To promptly handle your complaints, suggestions, and other requests, the Customer Service Provider needs to use your account and relevant information about the complained event to promptly understand, handle, and respond to related issues.
3.1.6 Implement data usage for security and analytics statistics
a. Ensure Usage Safety: We attach great importance to the security of accounts, services, and content. To safeguard the account and property security of you and other users and protect your and our legitimate rights and interests from illegal infringement, our partners may use necessary device, account, and log information.
b. Analyze product status: To analyze the usage and performance of our products, our partners may need to use information such as product usage status (crashes, sudden exits), Device ID information, and overall application installation and usage status.
c. Academic Research and Scientific Research: To enhance scientific research capabilities in relevant fields and promote the level of technological development, we may, on the premise of ensuring data security and legitimate purpose, use de-identified or anonymized data with cooperating scientific research institutions, universities, and other organizations.
3.2 Transfer
As our business continues to develop, we may engage in mergers, acquisitions, or asset transfers, and your personal information may be transferred as a result. In the event of the aforementioned changes, we will require the successor to continue fulfilling the obligations of a data controller in accordance with laws, regulations, and security standards no lower than those set forth in this Privacy Policy. If the successor changes the original purpose or method of processing, we will require the successor to obtain your authorization and consent again.
3.3 Public
a. We will not disclose your information, unless required by national laws and regulations or with your consent. When we disclose your personal information, we will adopt security protection measures that comply with industry standards.
b. When issuing penalty announcements regarding violating accounts or fraudulent activities, we will disclose information about the relevant accounts.
3.4 Personal information provided or disclosed with legal exemption from obtaining consent
Please understand that in the following circumstances, in accordance with laws, regulations, and national standards, we may provide or disclose your personal information to our partners without obtaining your prior authorization and consent:
a. Necessary for the conclusion and performance of a contract to which you are a party, or necessary for the implementation of human resources management in accordance with labor rules and regulations formulated in accordance with the law and collective contracts concluded in accordance with the law;
b. Necessary for the performance of legal duties or obligations;
c. Directly related to national security or national defense security;
d. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
e. Necessary for responding to public health emergencies or protecting the life, health, and property safety of natural persons in emergency situations;
f. Conducting activities such as news reporting and public opinion supervision for the public interest, and processing personal information within a reasonable scope;
g. Process personal information that you have publicly disclosed on your own or that has already been legally disclosed in accordance with relevant laws;
h. Collecting personal information from legally publicly disclosed information;
i. Other circumstances provided for by laws and administrative regulations.
4.1 Storage Location
We store your personal information collected and generated during the operation of this platform in Singapore and in the US in accordance with the provisions of laws and regulations. If it involves obtaining information from overseas or transmitting information overseas, we will strictly comply with the applicable relevant laws and regulatory policies, and will follow the relevant national regulations or seek your consent.
4.2 Storage Tenor
We retain your personal information only for the period necessary for the purpose of providing the services, for example: Mobile phone number: When you register and log in using your mobile phone number, we need to continuously retain your mobile phone number to provide you with normal services, handle your possible inquiries and customer complaints, and safeguard your account and System Security. Relevant information generated during your use of services and other processes on this platform (which needs to be adapted according to product circumstances) will be retained by us for the purpose of providing you with continuous business functions during the period when you have not completed, terminated, or cancelled the contract. We will delete or anonymize your personal information after you cancel your account, voluntarily delete personal information, exceed the necessary tenor, terminate or cancel the contract, except in the following cases: Comply with the requirements of laws and regulations regarding information retention (for example, the E-commerce Law stipulates that product and service information, as well as transaction information, shall be retained for no less than three years from the date of completion of the transaction). When it is necessary to reasonably extend the tenor for purposes such as finance, auditing, and dispute resolution.
5.1 We attach great importance to the security of your personal information and will strive to take reasonable security measures (including technical and administrative measures) to protect your personal information and prevent the personal information you provide from being misused or accessed, publicly disclosed, used, modified, damaged, lost, or leaked without authorization.
5.2 We will use encryption technologies, anonymization processing, and other relevant reasonable and feasible measures that are no less advanced than those of industry peers to protect your personal information, and implement security protection mechanisms to prevent your personal information from being maliciously attacked.
5.3 We will establish a dedicated security department, security management system, and data security process to safeguard the security of your personal information. We implement strict data usage and access policies to ensure that only authorized personnel can access your personal information, and conduct timely security audits on data and technology.
5.4 Although the above reasonable and effective measures have been taken and the standards required by relevant laws and regulations have been complied with, please understand that due to technological limitations and various possible malicious means, in the internet industry, even if we do our best to strengthen security measures, it is impossible to always ensure 100% security of information. We will do our best to ensure the security of the personal information you provide to us.
5.5 You acknowledge and understand that the systems and communication networks you use to access our services may encounter issues due to factors beyond our control. Therefore, we strongly recommend that you take proactive measures to protect the security of your personal information, including but not limited to using complex passwords, regularly changing passwords, and not disclosing your account passwords and related personal information to others.
5.6 We will develop emergency response plans and immediately activate them when user information security incidents occur, striving to prevent the impact and consequences of these security incidents from expanding. Once a user information security incident (such as leakage or loss) occurs, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation and possible impact of the security incident, the measures we have taken or will take to address it, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly notify you of the relevant situation of the incident through push notifications, emails, letters, and other relevant means. When it is difficult to notify each user individually, we will adopt reasonable and effective methods to issue announcements. At the same time, we will also report the handling of user information security incidents to relevant regulatory authorities as required.
5.7 Once you leave the Platform and related services, and browse or use other websites, services, and content resources, we will have no ability or direct obligation to protect any personal information you submit on software or websites outside the Platform and related services, regardless of whether you log in, browse, or use the above software or websites based on the links or guidance from the Platform .
We attach great importance to your management of personal information and make every effort to protect your relevant rights, such as querying, accessing, modifying, deleting, withdrawing consent authorization, canceling your account, filing complaints and reports, etc., regarding your personal information, so that you are able to safeguard your privacy and information security.
6.1 Changing or Revoking the Scope of Authorization
Change or right to object limit settings: You can directly contact us through online feedback, or Lumidex@bytedance.com. After revoking authorization, we will no longer collect information related to this permission. Unless required by laws and regulations, we need to retain your transaction records for the shortest tenor, and such transaction records will necessarily include the relevant information you intend to change or revoke.
Information processing for changing or revoking authorization: Specific business functions and services will require your information to be completed. After you revoke your consent or authorization, we will no longer be able to continue providing you with the functions and services corresponding to the revoked consent or authorization, nor will we process your corresponding personal information. However, your decision to revoke consent or authorization will not affect the personal information processing we have previously carried out based on your authorization.
6.2 Access Privacy Policy
You can view the full contents of this Privacy Policy on the [official website] - [Privacy Policy]. Please understand that the Platform and related services described in this Privacy Policy may vary depending on factors such as the phone model, system version, software application version, and mobile client you use. The final products and services are subject to the Platform software and related services you use.
6.3 Account Cancellation
You can contact us via Lumidex@bytedance.com to apply for account cancellation. We will process your application promptly upon receipt and respond to your request within 15 working days or the time limit required by laws and regulations. Before you cancel your account, we will verify your personal identity, security status, device information, etc. You acknowledge and understand that account cancellation is an irreversible action. After you cancel your account, we will delete relevant information about you or anonymize it, except as otherwise provided by laws and regulations.
6.4 Feedback and Complaint Reporting
You may file a complaint or report in accordance with the publicly announced regulations. If you believe that your personal information rights may have been infringed upon, or if you discover clues of personal information rights infringement, you may contact us via Lumidex@bytedance.com. We will respond to your complaint or report within 15 working days after verification.
6.5 Notification of Ceasing Operations to You
If we cease operations, we will promptly halt activities related to collecting your personal information, notify you of the cessation of operations in the form of individual delivery or public announcement, and delete or anonymize the personal information we hold about you.
The Platform is not directed at, and may not be used by, minors under the age of 13, and as described in our Terms, is restricted to individuals that are 18 years or older. The minimum age to use the Platform may differ depending on the country or region you are in. If you believe that we have collected personal information from or about a minor under the minimum age, please contact us using the details set forth in the “Contact Us” section.
8.1 In order to provide you with better services, the Platform and related services will be updated and changed from time to time. We will revise this Privacy Policy in a timely manner. These revisions constitute part of this Privacy Policy and have the same effect as this Privacy Policy. Without your affirmative consent, we will not reduce the rights you should enjoy under this Privacy Policy that is currently in effect.
8.2 After this Privacy Policy is updated, we will issue the updated version on the Platform and remind you of the updated content through the Platform announcement or other appropriate means before the updated terms take effect, so that you can timely understand the latest version of this Privacy Policy.
9.1 The Platform is provided by Poligon Pte. Ltd. and its affiliates (including branches, subsidiaries, etc.) and recognized third-party partners. If you have complaints, suggestions, or questions about personal information protection issues, you can send the problem to Lumidex@bytedance.com, and we will promptly respond to your complaints and reports after verifying your user identity.
9.2 If you have any questions, comments, or suggestions regarding the content of this Privacy Policy, you may contact us via Lumidex@bytedance.com.