FM Privacy Policy

Updated on: June 15, 2025

Effective Date: June 15, 2025

Version No.: 20220615V1.0

Excellent innovation limited (hereinafter referred to variously as "FM", "we", "us", or "our") is the provider and operator of FM application software and services (hereinafter referred to as "the Software"). We respect your privacy and are committed to ensuring the security of your personal information. In the process of providing the products or services (collectively referred to as "the Services"), we may collect and use your personal information with your consent or as required by applicable laws. This Privacy Policy (hereinafter referred to as "the Policy") is intended to help you understand how we collect, use, disclose, process, and protect the personal information you provide when using FM products or services, your rights with respect to that personal information, and how we safeguard those rights. The Policy applies to all FM products and services, including applications, mini-programs, Web pages, software development kits (SDKs), and application programming interfaces (APIs) for third-party websites and applications used on computers and mobile devices, or any other forms that may emerge in the future.

It shall be specially noted that the Policy is not applicable to the services offered to you by third parties. You may receive content or network links from third parties. Please be cautious about whether to access the links, content, products, and services provided by third parties. Before submitting your personal information to any third party, please carefully review its privacy policy.

To ensure that you fully understand the Policy and make your own decisions, we will explain the Policy as clearly as possible by underlying or highlighting the critical information (especially in bold, capital, underlined, and other forms). Moreover, when you use our services for the first time, prompts will pop up, reminding you to pay attention to and understand the core content of the Policy.

Please read the Policy carefully to understand our practices with respect to your personal information before using our products or services, submitting personal information to us, or granting us consent to collect your personal information, and please visit often to stay informed of updates to the Policy. We will post changes to the Policy (if any) through relevant products or websites to keep you informed of the same. By accessing our services after such notice, you agree to the updated privacy policy. You can view the "Update Date" at the top of the Privacy Policy page to confirm the latest update time.

If you have any questions, please feel free to contact us via

privacy.help@mbox.ng

You can also access the Policy via:

FM APP > My > About Us > Privacy Policy

The Privacy Policy will help you understand the following:

I. How We Collect and Use Your Personal Information

II. How We Store and Protect Your Personal Information

III. How We Share, Transfer and Disclose Your Personal Information

IV. How Is Your Personal Information Transferred Across Borders

V. Your Rights to Your Personal Information

VI. How We Process Children's Personal Information

VII. Third-Party Service Providers and Their Services

VIII. Supplements and Updates to the Policy

IX. How to Contact Us

I. How We Collect and Use Your Personal Information

(I) Overview

FM believes that fundamental privacy rights must apply equally regardless of where you live. That's why FM treats any information that relates to an identified or identifiable individual as "personal information" no matter where that individual may live, particularly name, identity, location, online identifier or physical, physiological, genetic, mental, or any other related characteristics that can reasonably be used to identify the individual.

We only collect the information necessary for special, specific, explicit, and legitimate purposes and shall ensure that your information will not be further processed for any other purposes. We will request your consent again if we intend to use your personal information for any purposes not specified herein.

We will collect your personal information, including 1) the information you provide directly (such as the nickname and avatar you provide when you sign in to the account and sign up for our marketing activities); 2) the information generated during your use of the Software (such as device information and service log information), which will be automatically collected by us; and 3) the information we acquire from other sources.

You have the right to decide whether to provide your personal information when using our products or services or when we request it. You are not required to provide personal information to FM at any time. However, choosing not to provide it may prevent FM from being able to provide you with certain products or services or respond to issues you may encounter and limit FM's ability to resolve them. We will only collect and use your personal information for the purposes stated herein. The following are examples explaining why we collect your personal information:

(II) FM's Main Service Functions and Information Collection and Usage Scenarios

This Software has been designed to provide you with services to search and browse audio and video and create push notifications and channel subscriptions.

1. Providing Account Login Services

To derive the maximum benefit from Software functions and services, you must log in with your system account and follow instructions to access the appropriate account service interface. When you do so, we will collect your system account Open ID. We will bind your system account to your FM account. The personal information we obtain will be based on the authorized content of the system account, and you can access the privacy policy for it on the system account service page.

Should you refuse to provide this information, you will not be able to log in to FM to use the related functions. However, this will not affect your ability to use other FM functions, and you will still be able to browse and access basic Software service functions in guest mode (i.e., without registering as a user).

When you use the Software, we will assign you a random account nickname, and you may choose to add an avatar (including a real picture). At that time, we will request access to your camera, file, and media permissions. Refusing to grant these permissions will prevent us from helping you set or update your avatar but will not otherwise affect your ability to register or log in. You can revoke these permissions at any time by long-pressing the FM icon > App Details > Permission Management > Camera/Storage Permissions.

2. Providing Audio and Video Services

(1)When you enable our Services, we will collect your country and city information to provide content tailored to your location and to push relevant local news. At that time, we will request access to your location permissions. You can revoke the permissions at any time by long-pressing the app icon > App Details > Permission Management > Location Permission. Refusing to grant location permissions will prevent us from being able to determine your city automatically. You will be able to select your city from our city list manually.

(2)When you use our Services to search and browse audio and video content of interest, we will store your search and browsing history generated on this device on our servers to display your history and make it easier for you to use the Services. When you use the Services to download your favorite resources, we will request file and media permissions. Refusing to grant these permissions will prevent us from being able to download or save the relevant resources for you.

(3)When you subscribe to albums you like, we will collect your subscription records to notify you when album content is updated.

3. Providing Participation in Promotional Activities

From time to time, we will initiate or provide promotional activities. When you participate in these activities, we will collect information you voluntarily provide to us through the activity interface, such as your name and contact details. This information is mainly for us to get in touch with you and to award prizes. Should you refuse to provide the information required to participate in the promotional activity, we may be unable to provide you with the Services, prizes, or rewards. However, this will not affect your use of other functions of the Software.

4. Advertising and Marketing Service

During your use of FM products and services, our business partners may collect information about your device and general location. They may display promotional content on your phone's notification bar. We will be working throughout this process to ensure the security of your privacy.

We may create user profiles (placing your personal information into one or more fields) by analyzing the above information and establishing user groups. Targeted ads will only be displayed with your consent and in compliance with applicable laws.

We may combine the above information with others (including information across different services or devices such as computers, mobile phones, and other connected devices) to provide and improve our products, services, content, and ads. You retain the right to opt out of receiving personalized ads (if applicable) and object to user profiling analysis (if applicable), including identity analysis for direct marketing and automated decision-making purposes. To exercise these rights, you can enable/disable them anytime in Settings or by privacy.help@mbox.ng. Methods of opting out may vary by version.

Please be mindful that any information you submit on ad pages will be collected and used by third party advertisers or ad companies, who will be responsible for protecting your personal information. You will be subject to the Privacy Policies of third parties when using their services. Please read the policies carefully.

5. Messaging push service

We may also push service notifications, events, prizes, and other messages to you based on your device identifier, operating system version, current device username, network information, and information related to your use of the app. To withdraw consent and unsubscribe from notifications, events, prizes, and other messages, long-press the app icon > App Details > Notification Management. Methods of opting out may vary by version.

6. Improving Our Products or Services

We may also collect information about your device and service log to ensure proper functionality, improve our products and services, and optimize the product interface. Specifically:

(1) Information about your device and SIM card: When you start using the Software, we receive and record information about your mobile device (including brand, model, OS version, unique device identifier (UDID), CPU model, settings, system language, network device hardware address, and IP address of the mobile phone, and software and hardware characteristics), the Google Advertising ID (GAID) of the hardware device, information about the location of the mobile device (including the country or region where your mobile phone is authorized, and network access mode), and SIM card information based on how you interact with the Software and the specific permissions granted when installing and using the Software.

(2) Service log information: When you use the Software, we automatically collect information about how you use our service and save it as service logs. This includes the published information, access time, number of times you open the software, duration of use, event information (errors, crashes, restarts, and upgrades), browsing records, click records, playback records, and other log information generated by your devices when you are using the Software.

Please note that device information or service log information alone is not sufficient to identify a certain natural person. Any non-personal information used in combination with other information to identify a specific natural person or in combination with personal information will be regarded as personal information. In this case, with your authorization or unless otherwise provided for by laws and regulations, we will anonymize and de-identify such personal information.

Please note that we may also collect the device and service log information mentioned above for varying business functions and scenarios of the Software. (The collected specific information may differ depending on the business function and scenario.)

(III) Other Situations where Your Information May Be Collected

Where permitted by laws, we may collect your personal information from other individuals, business entities, public channels, or other third parties indicated by you, other partners who help us provide our products or services or assist us in ensuring information security and preventing frauds, and other legitimate avenues. We will inform you and collect your information with your consent.

We may also collect other information about you, your device, or your use of the Services in other ways that will be described to you at the time of collection for your consent.

To improve our product layout and offer you better services, we may carry out researches, statistical analyses, and predictions on the collected information in an anonymized manner (including machine learning or model algorithm training based on anonymized data). We will take technical measures and other necessary actions to process the collected personal information so that such information cannot identify any individual person and cannot be recovered. As permitted by applicable laws and regulations, we do not need to inform you separately for your consent for the use of such anonymized data.

II. How We Store and Protect Your Personal Information

1. How we store your personal information

We will store your personal information that we collected upon your consent in accordance with the relevant national laws and regulations concerning personal privacy and data protection. We may also store the personal information we collect in countries or regions other than the country in which we do business, provided that local laws and regulations do not prohibit such storage.

FM may store your personal information in Frankfort. Specifically:

The personal information collected and generated during our operations will be stored on servers located in Frankfurt.

We may use the servers in other areas or countries depending on our business development, and in such cases, we will update the Policy accordingly.

Whether personal information is stored in the country where we do business or in another country or region without violating the law, we will store it in accordance with the relevant laws and regulations regarding data storage. We will take necessary security measures considering the characteristics, scope, purposes of personal information processing, the possible risks in processing personal information, and the serious consequences in case of any damages. For example, we will encrypt and de-identify the collected personal information before storage. We will store the information only necessary for our business development within the minimum retention period unless otherwise permitted by laws or you agree to extend the retention period. We will delete or take other appropriate measures to delete data that exceeds the retention period or that you request us to delete, provided that this does not violate the relevant laws and regulations.

2. How we protect your personal information

We will also take other necessary measures to protect your personal information from misuse, unauthorized access, modification, disclosure, or destruction.

We implement security measures designed to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks, and we use administrative, technical and physical safeguards to protect your personal information by considering the nature, processing methods, and security of the personal information. We will continuously strive to improve these measures to keep your personal data secure.

It should be noted that no measures can absolutely guarantee the avoidance of data storage security incidents. In the event of a security breach, we will report to the appropriate regulator in accordance with the requirements of relevant laws and regulations, and provide the type of personal data involved in the data breach, the number of data subjects, the possible consequences of the data breach, and the remedial measures we intend to take in accordance with the requirements of the supervisory authorities. We will take all possible measures to remedy or mitigate the damages and consequences caused by a data breach. If permitted or required by laws, we will promptly inform you of the consequences or significant damage that may be caused to you as a result of a data breach, so that you can take appropriate measures to protect your rights to the greatest extent.

Since no website, Internet transmission, computer system, or wireless connection is absolutely secure, in addition to the necessary security measures we take, users need to be more aware of privacy and security risks. For example, if you are redirected to a third party's website, link, product, or service through our service, please be careful and read the terms of agreement of such website, link, product, or service carefully for the security of any data information collected by such website, link, product or service, and we will not be liable for any data security issues caused by such third party. If you find that certain content, advertisements, or features of our website, products, or services may be provided by third parties and may endanger your privacy and security, please contact us promptly and we will give priority to dealing with them in accordance with the law.

III. How We Share, Transfer and Disclose Your Personal Information

We will share, transfer, and disclose your personal information to the minimum extent and only when it is necessary for operations or required by laws. We will not share, transfer, or disclose your personal information unless otherwise required or permitted by applicable laws and regulations in the following circumstances:

1. How we share your personal information

We do not sell any personal information to third parties. To offer you timely service, we may share your personal information with our affiliates. We will only share your information with FM affiliates for lawful purposes clearly stated and only as necessary to provide the Services subject to the purposes stated in this Privacy Policy. For any purposes not covered herein, we will make explicit statements in the privacy policy or notice for the specific product or service.

We may share necessary personal information with authorized third-party partners (including technical service providers, data storage service providers, after-sales service providers, marketing service providers, and third-party SDK providers, among others) to perform certain functions or to provide you with better services and user experience. For example, to enable you to share information, use location services, or other rich and diverse services and features on third-party platforms, we may embed software development kits (SDKs) or other similar applications from authorized partners in the Software (which we subject to strict security checks to protect data security). We will share that information to the minimum extent and only when it is necessary for operations or required by law. Before sharing, we will sign stringent confidentiality agreements with our authorized partners, requiring them to take relevant confidentiality and security measures to process personal information in accordance with the Policy and the applicable laws of your jurisdiction. Moreover, we will require them to provide data security functions and information security qualifications (such as classified protection assessment, information security management system, etc.).

When embedding SDKs or any other similar applications of our authorized partners in the Software, we will do our due diligence to request the SDKs that obtain the information to protect the security of your data. Specifically:

We may also share your non-personal information with third parties to provide evaluation, analysis, or other business services. For example, we may use the aggregated information to help our partners (such as advertising service providers) understand the effectiveness, feedback, and usage trends of their services.

In the event of a merger, acquisition or bankruptcy and liquidation, transfer of assets, or other related transactions involving the transfer of personal information, we will require by agreement or other appropriate measures that the company or organization newly holding your personal information continues to be bound by the Policy and that such subject takes confidentiality and security measures no less stringent than those required by the Policy to handle personal information.

2. How we transfer your personal information

FM will not transfer your information to any other party unless:

(1) your express consent is obtained.

(2) Providing notice via email and/or our website or by means of another appropriate method to inform you of any changes in your ownership of, rights to, and choices regarding your personal information when FM is involved in a merger, acquisition, or sale of all or part of its assets that may affect your personal information.

(3) the transfer has been stated in the Privacy Policy or otherwise notified to you.

3. How we disclose your personal information

FM may disclose your personal information as required by law, legal procedures, litigation, and/or government departments and authorities. We may also disclose your personal information if the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance.

In addition, we may share your personal information with the following people:

(1) our lawyers, accountants, auditors, or similar consultants, when we request them to provide professional advice.

(2) investors and other related third parties, if actual or potential sales or other transactions with another company occur and are related to entities within the TECNO group.

(3) other third parties, for example, when specific information is disclosed to them under your authorization.

IV. How Is Your Personal Information Transferred Across Borders

For the purposes described in the Privacy Policy, we may transfer your personal information to the resources or servers mentioned in Section III of the Policy for storage or processing, and we may also transfer your personal information to third-party service providers and business partners, and therefore your data may be transferred to other countries or regions, subject to compliance with applicable laws and regulations in your region and with your authorized consent. The privacy laws in these countries or regions may differ, and the jurisdictions in which these servers are located may or may not protect personal information to the same extent as those in your jurisdiction. However, we will still strive to protect your personal information based on our Privacy Policy and carry out the cross-border transfer and other processing of corresponding information as required by the laws of the country or region where the personal information is located.

If we transfer personal information outside of your jurisdiction, whether to our affiliates or to a third-party service provider, we will comply with the relevant applicable laws. We will take appropriate security and protection measures to ensure that all such transfers are subject to the requirements of applicable local data protection laws.

V. Your Rights to Your Personal Information

As a data subject, you have a number of rights with respect to personal information such as confirmation, access, correction, deletion, withdrawal of consent, complaints (hereinafter referred to as "requests"), etc. We fully understand and respect these rights, which are also subject to specific exclusions and exceptions in accordance with applicable law. We will also take active steps to ensure that your rights are effectively guaranteed. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we charge no fees for your legitimate requests. However, for repeated requests exceeding reasonable limits, we will charge a reasonable fee to the extent permitted by applicable laws based on actual administrative costs as appropriate. We may deny requests that are unwarrantedly repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes in current practices), pose a risk to the legal rights of others or are highly impractical, or violate mandatory legal requirements.

1. Right to confirm and access: We inform you of how we collect and process your personal information via this Privacy Policy or through privacy policies or notices for specific product service scenarios. You have the right to confirm or reject such collection and processing by checking the box or via other methods. However, if you reject the service, some functions that require your express authorized consent before use may no longer be available. The personal information you have provided to us can be accessed directly from the interface of our products or services. In case of a failure to access information, email us at privacy.help@mbox.ng, and we will deal with your request promptly.

2. Right to correct and delete: When your personal information changes, or when you find that the information we collected and processed is inaccurate or incomplete, you have the right to request that we make corrections or additions. For some of your personal information, you can correct and amend it directly on the relevant function page of the product or service. You have the right to request us to delete your personal information when we have achieved the purpose of collecting your personal information or it is no longer necessary, or when you find that we have collected or processed your personal information in violation of the provisions of laws and regulations or the terms of the Privacy Policy. For any information you cannot access to correct or delete, email us at privacy.help@mbox.ng to request a correction or deletion.

It should be noted, however, that we may not be able to approve your request for deletion in certain cases, such as the deletion of transaction data, as FM is legally obliged to keep records of transactions in compliance with applicable local laws. Please also note that if you request the deletion of your information from our products and services, due to certain applicable local laws and technical limitations, we may not immediately delete the corresponding information from our backup systems, but we will securely store your personal information and prevent its further processing until the backup systems are updated and your information can be deleted or anonymized.

3. Right to withdraw consent: For our different products or services to perform the corresponding functions, we will require the necessary personal information in accordance with the applicable local laws. This is described in "How We Collect and Use Your Personal Information" of the Privacy Policy. You may withdraw consent previously granted to us for specific purposes, including the collection, use, and/or disclosure of your personal information in our possession or control, by deleting the information, disabling the functionality of the device, or withdrawing the consent request. You can email us at privacy.help@mbox.ng for relevant operations. We will process your request within a reasonable time after you send it, and then will not collect, use, and/or disclose your personal information according to your request.

Withdrawing your consent may result in an inability to continue to access certain and/or all FM product and service functions. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.

4. Right to complain: Email us at privacy.help@mbox.ng for any complaints that may arise. We will respond promptly to your complaint. If you are not satisfied with our response, especially if our personal information processing practices have harmed your legitimate rights and interests, you may also file a complaint or report to the local statutory personal data protection authority, or file a lawsuit with a court of competent jurisdiction.

5.  Right to control your privacy settings

You have the right to control your privacy settings, which allow you to restrict our collection, use, disclosure, or processing of your personal information. For example, you can choose to turn on or off the functions and permissions of Location Access, Camera, and SMS. You can also get more detailed information about the security status of your device in Settings. If you have previously agreed to enable the corresponding permissions or agreed to our use of your personal information based on the aforementioned business scenario and would like to change that, go to Settings > App Management > Permission Management or contact us at privacy.help@mbox.ng.

6. Right to cancel a service or an account

You can request that your account be cancelled via the cancellation path provided in the Services or by contacting us at privacy.help@mbox.ng. Please be careful when you cancel your account. You understand that after you cancel your account, we will stop providing products and services based on that account. Unless otherwise required by applicable laws in your region, we will delete the corresponding personal data under your account at the same time. If you sign in to the Services through a third-party account, please request the third party to cancel your account.

7. Right in some jurisdictions

Please pay attention that you may have the following data subject rights under applicable laws in certain jurisdictions:

(1) Right to restriction of processing. You have the right to request our restriction on your personal information processing. We will review the reasons for your request. If the reasons are in accordance with applicable data protection laws, we will process your personal information only to the extent permitted by such laws and will notify you before lifting the restriction on processing.

(2) Right not to be subject to automated decision-making. You have the right to refuse automated processing of your information, including performance analysis and other automated processing that may have a legal or similar impact on you.

(3) Right to data portability. You have the right to request the transfer of your personal information to another data controller in a structured and commonly used format.

While we also have the right to refuse to process your request, we may reject some of your requests where an exemption applies or where we comply with applicable laws. For example, some requests are manifestly unfounded or excessive or require disclosure of third-party information.

VI. How We Process Children's Personal Information

We do not provide products and services for children under the age of 14 or the equivalent legal age under the law in your jurisdiction (the legal definition of a child varies from country to country, and we will define a child based on the laws and regulations of the country or region in which we do business). We do not actively collect personal data from children and do not use it for marketing purposes. If you find that you have transferred information about such children to us, email us at privacy.help@mbox.ng, and we will remove the information as soon as possible. If we find that we have collected children's personal information, we will also remove the relevant content as soon as possible.

VII. Third-Party Service Providers and Their Services

When using FM products or services (such as life service and online customer service), you may receive links to third-party websites or content and services provided by third parties other than us, and some products or services may be provided in the form of SDKs or other means. You can choose whether to access or accept websites, products, and services provided by third parties based on your judgment. Our Privacy Policy does not apply to products and services provided by any third party. Since we do not have substantial control over a third party, we cannot be responsible for the collection and processing of your personal information by that third party. When you submit any information to that third party, please be aware of that third party's privacy policy and take care to protect your personal information.

VIII. Supplements and Updates to the Policy

We reserve the right to update or modify the Policy from time to time as our business, technology, applicable laws, and operations change. In case of any change to the Policy, we will notify you by posting the updated Policy here (on this page), or within the FM app under My > Settings > Privacy Policy, or by sending it to you as a separate notice. Please regularly check this page or the notifications we send you to stay informed of updates to the Privacy Policy. The Privacy Policy is subject to change, but we will not diminish your rights under the Policy without your express consent.

We will seek your express consent as required by applicable laws before we collect other information from you or use or disclose your information for a new purpose. If you continue to use products and services on the website, mobile device, and/or any other devices, you will be bound by the updated Privacy Policy.

The content of FM products or services stated in the Policy may change depending on the type of product and system version you are using, or the requirements of local laws and regulations.

IX. How to Contact Us

If you have any suggestions, questions, or concerns about our Privacy Policy or practices regarding the protection of personal information, contact us at:

Email: privacy.help@mbox.ng (Note: The email is used for receiving emails related to our Privacy Policy or our information protection only)

We will review your request regarding privacy or personal information as soon as possible and reply to you within 15–30 days after verifying your user identity. If your request involves complex or significant issues, we may ask you for further information.

If you are not satisfied with our response, especially if your legitimate interests have been violated by us, you can seek a solution from the relevant data protection supervisory authority in your jurisdiction. If you make the above inquiry to us, we will provide you with information on the relevant complaint channels that may apply to your case.

Thank you for your time to read our Privacy Policy!