This notice is prepared in accordance with Articles 14, 17, 29, and 30 of the Personal Information Protection Law of the People's Republic of China, and sets out item by item how this platform processes your sensitive personal information at the real-name verification stage. This notice is an integral part of the Privacy Policy; where it conflicts with the Privacy Policy, the stricter provisions of this notice prevail.
Version v1.0 · Effective date 2026-10-03 · Last amended 2026-10-03
Please note: The real-name verification stage involves your ID number and facial liveness detection, both of which are sensitive personal information as defined in Article 28 of the Personal Information Protection Law. The law requires your separate consent and notice of the purposes, methods, scope, and retention period of processing. This platform will not perform liveness detection until you have checked the consent box.
I. Basic Information on Our Processing of Sensitive Personal Information
Pursuant to Article 29 of the Personal Information Protection Law, we hereby give item-by-item notice as follows:
Item
Content
Sensitive personal information processed
① ID number (including name, date of birth, address, and other particulars recorded on the document) ② Facial image (collected by liveness detection, used only for instant comparison for identity verification) ③ Mobile number (to verify consistency with real-name information)
Purpose of processing
To verify the consistency between you and the identity information submitted, and to confirm your true identity, for use in: · Evidence anchoring and rights confirmation (the rights holder must be traceable to a real person) · Identity confirmation of both buyers and sellers in authorized transactions · Withdrawal and settlement (to prevent impersonation for collection) · Identity verification of the handling person for enterprise/creator certification · Retention of transaction records required by laws and regulations
Method of processing
The ID number is entered manually by you or confirmed by you after OCR recognition; the facial image is compared with the facial reference database through a liveness-detection algorithm; the mobile number is verified by verification code. The three must be mutually consistent for verification to pass.
Scale and scope of processing
Processed only when you initiate operations requiring identity confirmation such as real-name verification, withdrawal, enterprise certification, or transaction rights confirmation; no batch or background continuous collection is performed.
Retention period
ID number: retained for the duration the account exists. Facial image: used only instantaneously during verification, deleted immediately after verification, and the original facial image is not retained, with only the result record of "passed/failed" kept. Mobile number: retained for the duration the account exists. After account cancellation, deleted or anonymized within 15 business days, except for matters required to be retained by laws and regulations.
Cross-border transfer
By default, no cross-border transfer. All sensitive personal information is stored in cloud-service availability zones within mainland China. If the authentication service provider or liveness-detection service you select is provided by an overseas entity, we will notify you in advance and, as required, complete a cross-border transfer security assessment or execute a standard contract, and obtain your separate consent before processing.
II. Special Note on Facial Liveness Detection
Purpose limitation: Your facial image is used only for comparison in this identity verification. This platform will not use the facial image for advertising, user profiling, precision recommendation, member identification, or any other purpose unrelated to verification, nor will it build a facial database to provide services externally.
Non-retention principle: The facial image collected by liveness detection is deleted immediately after comparison and is not written to the storage system. We retain only the verification result (pass/fail/reason for failure), for the purpose of preventing circumvention of verification and handling appeals.
Not used to identify who you are beyond verification: Liveness detection is "confirming you are you," not "identifying who you are." After verification passes, this platform no longer has, nor retains, the ability to re-identify your identity.
Right to refuse: You have the right to refuse to provide facial liveness detection. But after refusal we will be unable to complete real-name verification, and consequently you cannot use services such as evidence anchoring, withdrawal, and transaction rights confirmation. Refusal does not affect your use of other functions unrelated to identity, such as the free, browser-based format-conversion tools.
Alternative: Where liveness detection cannot be performed (e.g., disability, severe facial injury), you may contact customer service to arrange an alternative verification method, and we will provide a feasible reasonable alternative.
III. Obtaining and Withdrawing Separate Consent
How obtained: Before you submit real-name verification, the page will display, in an independent pop-up with an independent checkbox, a summary of this entire notice and the processing rules above. Only after you actively check the box and click "Agree and Continue" will you enter the liveness-detection stage. The checkbox must not be pre-checked, nor may consent be obtained by means of "continuing is deemed as consent."
How withdrawn: You have the right to withdraw consent at any time. Withdrawal channel: send an email to privacy@ambervouch.com, stating your account and "withdraw consent to processing of sensitive personal information"; we will process it for you within 15 business days after verifying your identity. The in-site self-service entry "Account Settings → Real-name Verification Management → Withdraw Consent" will be launched together with the official site opening. Withdrawal does not affect processing activities already carried out on the basis of consent before withdrawal.
Consequences of withdrawal: After withdrawal, this platform will stop processing the relevant sensitive information and delete or anonymize the related data; but the loss of real-name status caused by withdrawal will simultaneously affect functions that depend on real-name identity (evidence anchoring, withdrawal, transaction rights confirmation).
Withdrawal does not affect other rights: Withdrawal of consent does not affect the rights you enjoyed on the basis of other processing grounds (such as necessity for performing a contract) before.
IV. To Whom We Disclose Your Sensitive Personal Information
Real-name verification service provider: To complete identity verification, we share the ID number, name, mobile number, and facial image for liveness comparison. We require it not to retain the facial image, not to use it for its own business, not to further provide it to third parties, and to sign confidentiality and compliance agreements.
Judicial and regulatory authorities: Where required by laws and regulations, or where genuinely necessary to protect the platform and others' legitimate rights and interests, we will provide it in accordance with the law and record the disclosure.
Beyond the above: We will not sell your sensitive personal information to any commercial entity, nor use it for any automated decision-making, profiling recommendation, or advertising targeting.
V. How You Exercise Your Rights
Pursuant to Articles 44 to 47 of the Personal Information Protection Law, you enjoy the following rights with respect to sensitive personal information, which we accept through the following accessible channels, free of charge:
Right
How to exercise
Access / Copy
Request by email to privacy@ambervouch.com (provided within 15 business days after identity verification); the in-site self-service entry will launch with the site opening
Correction
Request by email; changes to real-name information require re-submission of documents for processing
Deletion / Anonymization
Handled together at account cancellation; or requested separately by email
Withdraw consent
Email to privacy@ambervouch.com, stating "withdraw consent to processing of sensitive personal information"; the in-site self-service entry will launch with the site opening
Explain processing rules
By email; we will reply in writing within 15 business days
Complaint
service@ambervouch.com; you may also complain to competent authorities such as the cyberspace administration, telecommunications, public security, and consumer associations
Response time limit: We will reply within 15 business days after receiving your request and verifying your identity; where the matter is complex, it may be extended to 15 business days with an explanation.
VI. Legal Consequences of Refusing to Provide Sensitive Personal Information
You have the right to refuse this platform's processing of sensitive personal information, but you should understand the resulting functional limitations.
Statutory mandatory scenarios: Where laws and regulations or a competent authority's statutory requirement (e.g., taxation, retention of transaction records) mandate that certain information be provided, we will explain to you its legal basis and necessity in such cases.
Your refusal of real-name verification does not affect use of the platform's free tool-type functions; but rights-confirmation, transaction, and withdrawal services cannot be activated.
VII. Minor Protection
This platform's real-name verification service is intended for adults aged 18 or above.
Minors under the age of 18 who wish to use this platform's services must be operated by a guardian, who must provide the guardian's identity document.
Where we discover an account may have been registered by a minor, we will proactively contact the guardian to verify and delete the relevant information as needed.
VIII. Contact and Updates
Contact for the personal information protection officer: service@ambervouch.com (please indicate "Personal Information Protection Consultation")
This notice is updated together with the Privacy Policy. For material changes to the purpose, method, scope, or retention period of processing, we will re-obtain your separate consent and publish it on the site.
For changes in information processing caused by third-party reasons (change of authentication service provider, adjustment of liveness-detection supplier), we will likewise notify you in advance and re-obtain consent.
This notice is the Chinese-language authoritative text. If other language versions are provided in the future and a divergence in understanding arises between language versions, the Chinese version shall prevail.