Last Updated on July 24, 2025
This product (VirtuGo) is provided by Shenzhen Niu Xuejie Technology Co., Ltd. (hereinafter referred to as "VirtuGo," "we," or "the Company"). The registered address of the Company is Room 2504, Building 2, Jinlitong Financial Center, No. 1100 Xingye Road, Haiwang Community, Xinan Street, Bao'an District, Shenzhen, China. The contact information for our Data Protection Officer(DPO)is [email protected]. We attach great importance to protecting the privacy of users (referred to as "you" hereinafter) and are committed to respecting and protecting the personal information we collect. The data controller is Shenzhen Niu Xuejie Technology Co., Ltd.and its affiliated companies (including but not limited to TENORSHARE (HONGKONG) LIMITED ).
VirtuGo has appointed an EU representative in accordance with the Regulation No. 2016/679 on the protection of natural persons with regard to the processing of Personal Data (the “GDPR”). You can contact the designated EU representative of VirtuGo by reaching [email protected].
This Privacy Policy explains how we collect, use, store, share, and otherwise process your personal information when you use our products. This Privacy Policy will help you understand the following:
- I. How we collect your information, how we use it, and what information we collect from you
- II. How we store, protect, and transmit your personal information
- III. How we share, transfer, and disclose your personal information
- IV. How you shall manage your personal information
- V. How do we handle the personal information of minorsn
- VI. Permissions of users in different regions for their personal information
- VII. How the Policy will be updated
- VIII. How to contact us
Ⅰ. How we collect and handle your information, and what information we collect from you
1. The personal information we may need to collect and use about you regarding your use of our product includes the following two circumstances:
a. In order to provide you with the basic features of our product, we may need your permission to collect and use the necessary information. In the event that you refuse to provide the corresponding information, you will not be able to have proper access to or use our product.
b. In order to provide you with additional features of our product, you may have the option of accepting or refusing to provide us with certain information about yourself, and the type and scope of personal information collected for the basic features and additional features may differ. If you refuse to provide us with such information, you will not be able to use the additional features or reach the desired results, but this will not prevent you from using the basic features.
2. The specific scenarios in which we collect and use your information for functional purposes:
a. Using our products
①When you use our products/services, depending on the product type, we may request corresponding permissions and collect relevant data. Typically, we collect the following information:
- Device and Installation Information: Including device type, hardware model, operating system, software version, product serial number, installation data, etc.
- Product Usage Information: Including startup data, feature usage, interface clicks, login information, operation logs, access dates/times, usage duration, sizes/formats of processed files, crash data, etc.
- Feature Matching and Product Improvement: To match relevant features based on the information and potentially modify product appearance, adjust existing features, or develop new features according to analytical results.
- Facilitating, Evaluating, and Verifying Use: To facilitate, evaluate, and verify your use of our products and services.
- Statistical Analysis and Experience Enhancement: To conduct internal statistics/analysis and evaluate/enhance product experience by identifying user preferences and analyzing crash data.
- The categories of personal information we have collected about them;
- The categories of sources from which the personal information is collected;
- The business or commercial purpose for collecting or selling the personal information;
- The categories of third parties with whom we have shared personal information;
- The specific pieces of personal information we have collected about them (collectively, a “Request to Know”).
②We primarily collect this information for the following purposes:
③All collected information is anonymized, and we cannot directly identify your personal identity through this data.When switching the software to run in the background, due to limitations of certain device models and systems, information collection triggered by prior feature usage may not cease immediately, resulting in brief background data collection activities.
If you wish to object to our processing of your Product Usage Data and Product Installation Data for the purposes mentioned above, you may contact us via customer service or forms on our website.
b. Account Creation
To access and use our services, you may log in via a third-party account (such as Google). Currently, our product does not require you to create a local account, nor do we request or collect your username, email address, phone number, avatar, or similar identifiers.
When logging in through Google, we only receive the minimum data necessary for authentication, such as a secure identifier provided by Google (e.g., OpenID or encrypted ID). We do not access or store your Google nickname, profile picture, or email address unless explicitly authorized in the future.
At this time, we do not generate a persistent user profile based on your login, nor do we use this information for personalization, user profiling, targeted advertising, or cross-context behavioral tracking. We also do not sell or share this login information with any third parties.
If in the future we introduce features requiring profile information or account registration, we will provide additional notice and obtain your explicit consent before collecting such data.
c. Customer service and dispute handling
When you contact us or submit requests regarding sales, after-sales, or dispute resolution, in order to ensure the security of your account and the system, we may require you to provide the necessary personal information to verify your identity. To facilitate communication with you, assist in resolving your issues promptly, and document the handling process and outcomes, we may retain records of our communication, correspondence, and related content with you (including account information, address, email, other contact details, and any additional information you provide to substantiate relevant facts). Additionally, in order to provide customer service and improve its quality, we may utilize other information provided by you, including relevant information you provide during customer service interactions and questionnaire responses you submit to us during surveys.
d. Transactions and payments
When you make a payment for our product through the App Store/Google Play, the App Store/Google Play collects various payment information from you. The specific information collected depends on the policies of the App Store/Google Play. In the end, we obtain the following information from the App Store/Google Play: your Apple/Google ID and email, country/region, the first six and last four digits of your credit card account, credit card expiration date, billing address, the type of product you purchased, the amount you paid in your currency, subscription ID, and URLs related to the subscription (such as purchase confirmation page URL, subscription cancellation URL, and invoice PDF URL).
We will use the transaction and payment information to determine your subscription, grant you access to use our product, and keep records for our internal financial purposes.
We will not collect or process data related to your payment tools, such as credit card numbers, bank account numbers, or PayPal accounts.
e. Use of product features
When you use the location simulation feature of this product, we need to access your device’s cellular network or Wi-Fi permissions to establish an internet connection, which is the foundational prerequisite for implementing all online functionalities. And we need to access your device’s location permissions (or rely on mock location data provided by the device). The purpose of accessing location is to integrate Mapbox services, facilitating the display of your current (or simulated) location on the map and enabling you to retrieve, select, or input the location you wish to simulate on the map.
To achieve the location simulation effect, we will send your selected target location coordinate information (e.g., latitude and longitude) to our cooperative third-party service provider ip-api. ip-api will generate a simulated IP address and corresponding approximate geographical information (country, city, latitude/longitude, etc.) based on this coordinate information, and return this simulated IP and location information to our application.
We ourselves do not store the target location coordinates you select through this feature, the coordinate information sent to ip-api, or the simulated IP addresses or simulated location information received from ip-api. Per our agreement with ip-api, ip-api also explicitly states that it will not retain the coordinate information you submitted or the simulated IP/location data generated therefrom. This information is used solely for real-time processing of your individual request. All network-transmitted data involved in location simulation (including sent coordinates and received simulation results) exists only temporarily in memory during feature execution and is immediately automatically cleared after you close this feature or exit the application.
However, to enhance your user convenience, we locally store your retrieved location history records on your device. This data is saved only in your device’s local storage and is not uploaded to our servers or any third-party servers, facilitating your quick selection next time. You can typically manage (view or clear) this local history in the app settings.
f. Other content
You may provide reviews of our products in the software store's comment section or other public platforms. We will use the review information to improve our products, and we may use your posted reviews (along with your relevant information) for marketing purposes to provide information about our products to consumers and potential customers, enabling others to better understand and use our products.
During your use of our products, you may provide us with your information through data collection forms or other means. We will legally and compliantly use the provided information in accordance with the agreed terms and will not use it for other purposes.
3. We obtain the aforementioned permissions and information from you in order to provide specific services.
If you refuse to grant the corresponding permissions or disagree with us collecting such information, you will be unable to use the corresponding functionalities but can still use our other services without any impact.
II. How we store, protect, and transmit your personal information
Unless otherwise required or permitted by applicable laws for longer retention periods, we will determine different retention periods for different types of information based on the nature of the information, the purposes for which we use the information, and the duration necessary to achieve the purposes described in this policy. For example, when processing your information to provide you with services, we will retain your account information, billing information, and similar content for as long as you have an account with us.
We employ reasonable measures to help protect information from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. Please use complex passwords to assist us in ensuring the security of your account and personal information. Please be aware that the systems and communication networks you use when accessing our products may be subject to security vulnerabilities beyond our control. Understand that in the internet industry, due to technological limitations, rapid advancements, and potential malicious attacks, despite our best efforts to strengthen security measures, it is not possible to guarantee 100% security of information at all times.
Given the global nature of our business operations, we may transfer the data we collect about you to secure servers or data centers located in countries/regions outside the country where the data was initially collected (including the United States, the European Economic Area ("EEA"), or Japan) for storage and/or processing, The purpose of transferring this information across borders is:
- To transfer your payment information to payment processing companies located outside the European Union for transaction processing.
- To use third-party tracking tools (such as Bugsplat, Google Analytics) to track how users use product features. Product usage data may be sent to and stored in third-party servers located outside the European Union. Such tracking tools may share tracking data or analytics reports with VirtuGo for the aforementioned purposes. Our tracking tools anonymize your personal data.
- To store personal data on servers leased from service providers.
When transferring your data to countries/regions outside the country where the data was initially collected, we will protect the data in accordance with the instructions in this privacy policy and comply with applicable legal requirements to provide adequate protection for such data.
Ⅲ. How we share, transfer, and disclose your personal information
In order to ensure the implementation of our product-related features and the safe and stable performance of our apps, and because some features of our products cannot be executed by us alone, we may share or entrust some of your personal information with third parties such as our partners in order to ensure the smooth implementation of our product features. You agree that we may share your personal information with affiliates that support our features, and with third parties that we integrate or access, for the purpose of providing the services to you. The support provided by these third parties includes providing us with payment processing, data analysis, and location spoofing services. Our affiliates of our features are not authorized to use your personal information for purposes other than those set forth in this Privacy Policy and the purposes set forth herein. They shall obtain your authorized consent separately if they wish to change the purposes for which personal information is processed.
We may share your data with our affiliated companies, and in the event of a merger, division, acquisition, or bankruptcy liquidation, your data may be transferred as part of such transaction. We will ensure the confidentiality of such information during the transfer, inform you of the name and contact information of the recipient, and require the new entity holding your personal information to continue abiding by this personal information protection policy. Otherwise, we will request the recipient to seek your authorization and consent again. If we rely on your consent to process your personal data, you have the right to withdraw your consent at any time.
We may disclose all the information we collect about you for subsequent reasons: in response to subpoenas, court orders, legal proceedings, law enforcement requests, legal claims, or government investigations, to protect and defend the rights, interests, and safety of the platform, our affiliated companies, users, or the public.
IV. How you shall manage your personal information
You have the right to access, correct, and delete the information we collect about you. If you are unable to do so, or have any questions about Personal Information we have collected and/or shared about you, or would like to withdraw your consent for our processing (i.e. entirely delete your account) please contact us at: [email protected].
We will act on the User’s requests and provide information free of charge, except where the requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case we may charge a reasonable fee (taking into account the administrative costs of providing the information or communication, or taking the action requested), or refuse to act on the request.
V. How do we handle the personal information of minors
If you are a minor, you shall use our services with obtaining prior consent of your parent or legal guardian (collectively, "guardian"). We recommend that the guardians of minors shall read this Policy carefully, and we also recommend minors obtain guardians’ prior consent and guidance before submitting personal information in their use of our services. If you are the legal guardian of a minor, please ensure that the minor in your custody is using our products or services with your authorized consent. If you have questions about the personal information of a minor in your custody, please contact us through the means set forth in this Privacy Policy.
We are not directed to children under the age of 13 and we do not knowingly collect Personal Information from children under the age of 13. If we learn that we have collected the Personal Information of a child under the age of 13, we will take reasonable steps to delete such information from our files as soon as is practicable, unless we have a legal obligation to retain it. Please contact us if you believe we have any information from or about a child under the age of 13: [email protected].
Ⅵ. Permissions of users in different regions for their personal information
The GDPR,Law Concerning Protection of Personal Data of Japan, and other applicable data protection laws provide certain rights for data subjects. Broadly speaking you have, or may have, the right (as more fully provided in applicable data protection laws):
The right to be informed: The User has the right to be provided with clear, transparent, and easily understandable information about how VirtuGo collects and uses personal data and its rights. This is the reason why VirtuGo is providing the User with the information in this privacy policy.
The right of access: The User has the right to obtain access to its Personal Data (if VirtuGo is processing it), and other certain information (similar to that provided in this privacy policy).
The right to rectification: The User is entitled to have its personal data corrected if it’s inaccurate or incomplete.
The right to erasure: This ‘the right to be forgotten’ enables the User to request the deletion or removal of its personal data where there’s no compelling reason for VirtuGo to keep using it.
The right to withdraw consent: The User has the right to withdraw a previously provided consent to processing of your personal information.
The right to object to processing: The User has the right to object, on grounds relating to its particular situation, at any time, to the processing of its personal data.
The right to restrict processing: Under certain circumstances, the User has the rights to ‘block’ or suppress further use of its personal data.
The right to data portability: to receive its Personal Data provided to VirtuGo in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller.
The right to lodge a complaint: to complain about our processing of your personal information to a local supervisory authority.
It is important to be aware that these rights may not be absolute. For example, if you withdraw your consent to our processing of your personal information, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
In the event of a data leak, we will inform the regulatory authorities and users of the leaked information in a timely manner, If you have any questions about the matters covered by this policy, please contact our Data Protection Officer at [email protected]
Exercise the above rights, you can send an email to customer service email:[email protected], or fill out our request form here
Rights regarding personal information for California residents.
Pursuant to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), California residents receive certain rights with respect to their personal information, as described below. These rights are not absolute and are subject to certain exceptions more fully set forth in the CCPA.California residents have the right not to receive discriminatory treatment from us for the exercise of the privacy rights conferred by the CCPA.
California residents have the right to obtain access to their Personal Data (if VirtuGo is processing it), and other certain information (similar to that provided in this privacy policy).
California residents have the right to request that businesses stop selling or sharing their personal information (“opt-out”), including via a user-enabled global privacy control. Businesses cannot sell or share your personal information after they receive your opt-out request unless you later authorize them to do so again.
Each California resident has the right to request, subject to certain exceptions described in the CCPA, that we disclose to that resident:
California residents have the right to restrict our use of Sensitive Personal Information collected about them.
In the past twelve months, we have collected, and in the future, we will continue to collect, the categories of personal information cited in the section entitled “The personal information we collect” above. This includes the following categories of personal information set out in the CCPA: identifiers, personal information described in Section 1798.80 of the California Civil Code, characteristics of protected classifications under California or federal law, Internet or other electronic network activity information, geolocation data, professional or employment-related information, and sensitive personal information. We collect and use this information from the sources described in the section entitled “How we collect your information, how we use it, and what information we collect from you” above, and share this information with third parties as described in the section entitled “How we share, transfer, and disclose your personal information” above.
We do not sell your personal information as defined under the CCPA or share your personal information for cross-contextual behavioral advertising purposes and we do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. We do not use or disclose sensitive personal information for purposes other than those permitted purposes specifically identified in the CCPA and its implementing regulations.
Right to request deletion of personal information.
Each California resident has the right to request the deletion of the personal information that we collect or maintain (a “Request to Delete”), subject to certain exceptions set forth in the CCPA.
Process for verifying requests of California residents.
Each California resident has the right to request the correction of any inaccurate personal information that we maintain (a “Request to Correct”), subject to certain exceptions set forth in the CCPA.
To make the aforementioned Request, you can send an email to customer service email:[email protected], or fill out our request form here
Process for verifying requests of California residents.
In order to protect your privacy and security, prior to completing any Request to Know, Request to Delete, or Request to Correct that you may submit, we must verify your identity. We will verify your identity by asking you to provide certain data that we have already collected from you to confirm that they match our records. In certain instances, additional verification steps may be required.
Authorized agents.
California residents have the right to designate an authorized agent to make a request under the CCPA on their behalf. Prior to completing a request made by such an authorized agent, we require that you provide your authorized agent with written permission to submit such a request and require that you or your authorized agent provide us with a copy of such written permission. Additionally, we require that you verify your identity pursuant to the procedure described above.
Keeping personal information.
Your personal information will be retained in accordance with our Data Privacy Policy.
We retain personal information of different types, or relating to different categories of people, for different periods, taking into account its business purpose. For example, information about individuals who have applied for employment with us will be retained for a shorter period than information about individuals who have actually worked for us.
The periods for which we retain information are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used. We take into account legal and regulatory provisions which require information to be retained for a minimum period. We also consider the limitation periods for taking legal action and good practice in the legal industry.
If you have any questions on the matters covered in this policy, you can send an email to customer service email:[email protected].
Changes to our privacy policy.
We regularly review this Privacy Policy and may make changes as our services or privacy practices change, or as required by applicable laws or regulations. Future versions of our Privacy Policy will be available on our website. We encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.
Ⅶ. How the Policy will be updated
We may periodically update this Privacy Policy. When we make updates, we will notify you by updating the "Last Updated" date at the top of the revised Privacy Policy, posting the revised Privacy Policy, or providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you use our products to stay informed of any changes. If you disagree with the updated terms and conditions, you should cease accessing or using our products as of the effective date of the changes. The updated terms and conditions will not apply to you if you stop accessing or using our products. If you continue to access or use our products after the effective date of the changes, it will be deemed as your acceptance of the updated terms and conditions.
Ⅷ. How to contact us
If you have any questions, inquiries, opinions, suggestions, or complaints regarding this Privacy Policy or the protection of your personal information, you can contact us through our online customer service.
Additionally, you can reach out to us through the following means:
Send an email to our customer service email address: [email protected].
Submit an online form at https://support.ultfone.com/#/