Privacy Policy

Welcome to PowerWriter Programmer (hereinafter referred to as "this Software"). This Privacy Policy aims to clearly and comprehensively inform you of the data collection, use, storage, transmission, protection practices of this Software, as well as the various privacy rights you are entitled to by law. It clarifies the compliance basis and operational norms for data processing, and effectively safeguards the privacy security and legitimate rights and interests of users worldwide.

This Software strictly complies with the core requirements of the above-mentioned global mainstream privacy and data security regulations. All data processing activities are necessary for product improvement, chip adaptation, and vulnerability repair. No personally identifiable information is collected, and there are no commercial data utilization behaviors, adhering to the dual bottom lines of privacy protection and product optimization.

1 Scope of Data Collection

All data collection activities of this Software are strictly limited to the minimum scope necessary for product improvement. Data types are divided into pure anonymous usage data (statutory non-personal information, enabled by default) and optional device identification data (de-identified device information, requiring explicit user consent). Neither type involves any personally identifiable information or sensitive original device identifiers.

1.1 Pure Anonymous Usage Data

1.1.1 Legal Basis for Collection

This category of data is fully anonymized non-personal information with the statutory characteristics of "unable to identify specific users/specific devices and unable to be restored to identifiable information through any technical means". In accordance with Article 73 of China's Personal Information Protection Law and Article 2 of the EU GDPR, it does not fall within the scope of personal information, is not subject to the constraints of personal information processing rules such as "user consent", and may be enabled by default for product optimization.

1.1.2 Current Collected Content and Corresponding Purposes

Only anonymous data directly related to the use of this Software and product improvement is collected, with no irrelevant information. The specific collected content and their sole purposes are as follows:

• Basic system information: Operating system version (e.g., Windows 10/11, macOS Ventura, Linux Ubuntu, etc.), version number of this Software; Purpose: Adapt to different system operating environments, fix version-related program vulnerabilities, and optimize cross-platform compatibility.

• Software function usage frequency: Number of uses and single-use duration of each core function of this Software (batch programming, erasing, verification, reading, chip detection, etc.); Purpose: Analyze function practicality and user usage habits, optimize function layout and operation logic, and improve product user experience.

• Online/offline programming error statistics: Error type, error code, triggering function scenario, basic hardware connection status; Purpose: Quickly locate program vulnerabilities, optimize error handling mechanisms, and enhance the stability of online/offline programming.

• Chip usage frequency: Number of uses, programming success rate, and adapted software version of each chip model (e.g., W25Q64, AT25DF, STM32 series, etc.); Purpose: Prioritize adaptation of high-frequency used chips, optimize chip driver programs, and improve the overall chip adaptation coverage and success rate.

1.1.3 Supplementary Agreement for Future New Anonymized Data

To continuously optimize product experience and adapt to new chip models/system environments/function scenarios, this Software may add new anonymized data collection items not listed in this Agreement in the future. All such new additions will strictly follow the following principles and agreements, fully comply with global privacy compliance requirements, and will not harm any legitimate rights and interests of users:

1. Unchanged legal attribute: All new data shall be fully anonymized non-personal information that meets the statutory standards of "unable to identify specific users/devices and unable to be restored", and shall not involve any personal information or sensitive original device identifiers;
2. Limited collection scope: New data shall only focus on the three core purposes of product improvement, chip adaptation, and vulnerability repair, be directly related to the use of this Software, strictly follow the principle of "data minimization", and no irrelevant information shall be collected;
3. No exceptions to compliance framework: The collection, use, storage, and protection of new data shall strictly comply with all agreements in this Privacy Policy, including encrypted transmission and storage, no sharing with third parties, storage period of 1 year + secondary anonymization after expiration, etc., with no special handling circumstances;
4. No impairment of user rights: The addition of anonymized data shall not change the rules of this clause ("enabled by default, cannot be closed"), nor shall it restrict or weaken users' use of the core functions of this Software, or impose any additional obligations on users;

1.1.4 Collection Method

During the operation of this Software, data is automatically counted locally, anonymized, packaged, and silently reported without any manual intervention, no additional background processes occupying device resources, and no impact on the normal operation of core functions such as programming and erasing of this Software.

1.2 Optional Device Identification Statistics

1.2.1 Legal Basis for Collection

This category of data is de-identified device characteristic information used only to distinguish software instances and achieve refined product improvement, without associating with any personally identifiable information. In accordance with Article 13 of China's Personal Information Protection Law and Article 6 of the EU GDPR, explicit user consent is the sole prerequisite for data processing. It is disabled by default, and users have complete autonomy to choose whether to enable it.

1.2.2 Collected Content and Generation Rules

After users manually enable this function, this Software will randomly generate a unique Device Identifier (Device ID) based on non-sensitive device characteristics (only extracting non-unique characteristics of the system operating environment, excluding MAC address, hard disk/CPU/motherboard serial number, BIOS information, UUID, and other original information that can uniquely identify the device). The Device ID is a string of meaningless random characters that cannot reversely deduce any device information or associate with any personally identifiable information, and is only bound to the pure anonymous data specified in Clause 1.1 of this Agreement.

Sole Purpose: Distinguish different software instances, analyze device retention rate, single-device usage habits and error scenarios to achieve more precise product improvement, with no other uses.

1.2.3 User Operation Rights and Processing Rules

1. Enabling method: The function switch is solidified in the installation package of this Software, and can only be manually checked and enabled through 「Settings - Preferences - Participate in Product Improvement Program」 of this Software. The switch path is deployed synchronously with the installation package, with no mandatory pop-up guidance, no function bundling, and no inducement prompts;

2. Disabling method: It can be disabled with one click in the same path as above, with the same convenient operation process as enabling, complying with the statutory requirement of the EU GDPR that "consent and withdrawal of consent are equally convenient";

3. Processing after disabling: The disable instruction takes effect in real time, and this Software will immediately stop the generation, reporting, and local storage of the Device ID; The reported Device ID will be completely deleted from the server within 7 working days, no longer bound to any anonymous data, and this Software will revert to the pure anonymous data reporting mode;

4. No function restrictions: This Software will not restrict or weaken the usage rights of any core functions, nor harass or induce users in any form because users refuse to enable or subsequently disable this function.

1.3 Information Strictly Not Collected

The developer of this Software solemnly promises to never collect any data that can identify personal identity, involve sensitive device information, or is irrelevant to product improvement, including but not limited to the following categories:

• Personally identifiable information: Name, mobile phone number, email address, ID card number, passport number, social security number, social media account, system login account, payment information, communication records, etc.;

• Sensitive device information: MAC address, hard disk/CPU/motherboard/network card serial number, BIOS information, UUID, device IMEI/MEID, network card physical address, device unique identifier, and other original information that can uniquely identify the device;

• User usage traces: Content of local computer files, browser browsing history, device operation logs (except statistics related to the use of this Software's functions), precise geographic location (including latitude and longitude, positioning city/region), network IP address, device clipboard content, etc.;

• Other irrelevant information: Local files such as photos, videos, and documents stored on the device, usage data of other software, detailed information of device hardware configuration (except the basic environment required for product operation), data of other applications in the user's device, etc.

2 Purpose and Strict Restrictions of Data Use

2.1 Sole Purpose of Use

All data collected by this Software (including pure anonymous data and optional Device ID-bound data) is only used for the three core purposes of product improvement, chip adaptation, and vulnerability repair, specifically including:

1. Optimize the stability, compatibility, and operational experience of this Software, and adapt to system environments and network usage scenarios in different regions worldwide;

2. Improve chip adaptation coverage and programming success rate to meet the chip usage needs of users worldwide;

3. Quickly locate and fix program vulnerabilities during programming, reduce errors, and ensure the normal and stable operation of the core functions of this Software.

2.2 Strict Restrictions on Data Use

1. All data is only used for the clearly listed core purposes above, with no catch-all "other purposes"; If the purpose of data use needs to be changed due to major product adjustments, the developer will publicly announce through this Software and notify users separately in advance, and proceed only after obtaining explicit user consent;

2. The collected data will not be used for any commercial purposes such as commercial advertising, user profiling, precision marketing, or data transactions;

3. The data will not be used for any analysis, research, statistics, or other operations unrelated to the product improvement of this Software;

4. The data will not be used to identify or track users' personal identities in any way, nor will the data be correlated and matched with any third-party personal information.

3 Data Storage and Protection

3.1 Data Storage Specifications

The data storage of this Software strictly follows the principles of "localization, minimization, and timeliness", complying with global data security regulatory requirements. The specific specifications are as follows:

1. Storage subject: All data is independently stored by ICWorkshop Technology (Shenzhen) Co., Ltd., the developer of this Software, with no participation of any third-party institutions in the data storage process;

2. Storage servers: Stored on regular cloud servers that meet global data security standards, supporting compliant deployment at home and abroad; Among them, data of users in the EU region is uniformly stored on compliant servers within the EU, in line with the statutory requirement of GDPR for "data localization";

3. Storage period:

• Pure anonymous data: The storage period is 1 year. After the expiration, secondary anonymization processing will be conducted (all associable field information will be deleted, only aggregated statistical results will be retained, and no single piece of data can be traced);

• Optional Device ID-bound data: Stored from the date the user enables the function, and will be completely deleted within 7 working days after the user disables the function, with no retention in any form;

4. Storage minimization: Only core data necessary for product improvement is stored, with no redundant data storage. The developer will conduct quarterly cleaning and verification of server data to ensure that data storage complies with the principle of minimum necessity.

3.2 Full-Process Data Protection Measures

This Software adopts internationally accepted advanced data security encryption technologies to strictly protect the entire process of data transmission, storage, and processing, complying with the data security statutory requirements of China's Cybersecurity Data Governance Regulations and the EU GDPR. The specific protection measures are as follows:

1. Data transmission: HTTPS/TLS 1.3 encryption protocol is used for data reporting and transmission to ensure that data is not leaked, tampered with, or stolen during transmission;

2. Data storage: AES-256 encryption algorithm is used for encrypted storage of server data. The server is equipped with multi-layer access control, and only core R&D personnel of this Software (all signed non-disclosure agreements) have limited access. All access operations are fully logged and traceable;

3. Data processing: All data is subject to aggregated analysis on the server side, with no manual review of any single piece of data. The analysis results are only used for the product improvement of this Software;

4. Device-side protection: This Software has no background processes to steal device data, no additional device permission applications (such as device storage, location, contacts, camera, etc.), and does not read or access any irrelevant files and data on the local device.

3.3 Data Sharing, Transfer, and Disclosure

The developer of this Software will never sell, lease, lend, or share any collected data (including pure anonymous data and optional Device ID-bound data) to any third party, nor transfer the data to any third-party subject (including but not limited to advertisers, data service providers, other enterprises, individuals, etc.).

Sole Exception: When required to cooperate in providing data in accordance with applicable laws and regulations or the legitimate and formal requirements of judicial/regulatory authorities, the developer will, within the scope permitted by law, only provide the necessary minimum scope of data, explain the anonymized/de-identified nature of the data to the relevant authorities, and make every effort to take reasonable measures to protect users' privacy rights and interests.

This Software will not publicly disclose any user-related data; If it is necessary to publish product-related statistical information, only aggregated anonymous statistical results will be released, which cannot identify any user or device.

3.4 Compliance with Cross-Border Data Transmission

For users in the EU region, if this Software involves cross-border data transmission, it will strictly comply with Article 44 of the EU GDPR and adopt the Standard Contractual Clauses (SCCs) approved by the European Commission as the compliance basis for cross-border transmission;

For users in other overseas countries/regions, corresponding cross-border transmission compliance measures (such as adequacy determination, binding corporate rules, local data storage, etc.) will be adopted in accordance with the local privacy and data security regulatory requirements to ensure the legality, security, and compliance of cross-border data transmission.

4 Statutory Rights of Users

In accordance with global mainstream regulations such as China's Personal Information Protection Law, EU GDPR, and California CCPA/CPRA, as a user of this Software, you are entitled to the following privacy rights by law. The developer of this Software will provide convenient, free, and barrier-free channels for you to exercise these rights, with no additional conditions, and will not discriminate against you for exercising the following rights.

4.1 Right to Independent Choice

You have the right to independently choose whether to enable the "Optional Device Identification Statistics" function, and can disable it with one click at any time after enabling. The entire operation process is completed within this Software, without the need to provide any personal information; This Software will not restrict or weaken the use of any core functions, nor harass or induce you to enable the function because you refuse to enable or disable it.

4.2 Right to Know

You can access all details and operational norms of data collection, use, storage, and protection of this Software at any time through this Privacy Policy and the 「About - Privacy Policy」 entry of this Software; If you have any questions about data processing-related matters, you can consult through the contact information specified in Clause 6 of this Policy, and the developer will give a clear and definite reply within the statutory time limit.

4.3 Right to Access, Copy, and Correct

If you have enabled the "Optional Device Identification Statistics" function, you may apply to the developer to access and copy the Device ID-bound data related to your device; If you find errors in the relevant data, you may apply for correction, and the developer will complete the verification and processing within 15 working days and feed back the results to you in writing.

Note: Pure anonymous data is non-personal information that cannot identify any user/device, so separate access, copy, correction, and other operations are not supported.

4.4 Right to Delete

1. If you have enabled the "Optional Device Identification Statistics" function, you can disable it with one click through this Software at any time, and apply to the developer to completely delete the relevant Device ID-bound data. The developer will complete the deletion within 7 working days and feed back the processing results to you;

2. If you meet the deletion conditions specified by local laws and regulations (e.g., the purpose of data processing has been achieved, you withdraw consent, the data processing behavior violates laws and regulations or this Privacy Policy, etc.), you may apply to delete the relevant data, and the developer will verify and process it in accordance with the law.

4.5 Right to Complain and Report

1. If you believe that the data processing behavior of this Software violates this Privacy Policy or relevant laws and regulations, you may complain to the developer through the contact information specified in Clause 6 of this Policy. The developer will complete the verification and processing within 15 working days and feed back the results to you in writing;

2. If you are not satisfied with the developer's handling result of the complaint, you may report to the data protection regulatory authority of your country/region (such as Cyberspace Administration of China, EU EDPB, California AG, etc.), and the developer will actively cooperate with the investigation and processing work of the regulatory authority.

4.6 Right to Non-Discrimination

The developer of this Software will not discriminate against you in terms of software use, function provision, service quality, etc. for exercising the above statutory rights, and fully protect your legitimate use rights and interests.

5 Policy Updates and Sufficient Notification

5.1 Principles for Policy Updates

Updates to this Privacy Policy will strictly follow the principles of "legality, necessity, transparency, and no impairment of rights", and will only be adjusted in the following circumstances:

1. Changes in applicable privacy and data security laws, regulations, and regulatory requirements;

2. Reasonable changes in the product functions or data processing methods of this Software;

3. To improve the level of user privacy protection and perfect the compliance mechanism and data protection measures.

After the policy update, the developer's obligations for privacy protection and data security will not be reduced, nor will the legitimate rights and interests of users be unilaterally harmed.

5.2 Methods of Update Notification

After the update of this Privacy Policy, the developer will provide sufficient notification through the following multiple methods to ensure that you are timely informed of the updated content and key changes:

1. Publish an official update announcement at the 「About - Privacy Policy」 entry of this Software, clearly marking the updated content, key changes, and effective date;
2. Display a pop-up prompt on the startup page of this Software (the pop-up will be retained for 7 natural days), clearly guiding you to review the updated Privacy Policy;
3. Notify separately users who have enabled optional device identification statistics through the official contact information specified in Clause 6 of this Policy to ensure that these users are fully informed.

5.3 Effective Rules

1. After the policy update, the new policy will take effect officially 30 days from the date of public announcement, reserving sufficient time for you to review, understand, and consider;

2. If you continue to use this Software after the new policy takes effect, it shall be deemed that you have read, understood, and agreed to all the terms of the updated policy; If you do not agree to the updated policy, you may stop using this Software, and the developer will immediately stop all data collection activities and process the collected data in accordance with the agreements of this Policy.

6 Official Contact Information

If you have any questions or suggestions about this Privacy Policy, or need to exercise the statutory rights specified in Clause 4 of this Policy, you may contact the developer through the following official, valid, and sole methods. The developer will handle and feedback professionally and timely within the statutory time limit:

• Official customer service email (preferred processing channel): cs@icworkshop.com (response within 1 working day, completion and feedback within 15 working days)
• Official customer service phone: 400-1568-598 (Service hours: 9:00-18:00 on legal working days in mainland China, excluding legal holidays)

7 Other Supplementary Clauses

7.1 Protection of Minors

This Software is a professional chip programming tool software, mainly targeting professional users such as enterprises, engineers, and professional technicians, and does not provide services to minors. If it is found that a minor uses this Software without the consent of a guardian, the developer will immediately stop all data collection activities and require the guardian to guide and stop the minor's use.

7.2 Compliance Assessment and Optimization

The developer will regularly conduct a Personal Information Protection Impact Assessment (PIA) for the data processing behavior of this Software (for optional device identification data), and continuously optimize the data processing methods and privacy protection measures based on the assessment results to ensure that all data processing behaviors of this Software always comply with the requirements of global mainstream privacy and data security regulations.

7.3 Dispute Resolution

1. The establishment, entry into force, performance, interpretation, and dispute resolution of this Privacy Policy shall be governed by the relevant laws and regulations of your country/region; If there are no clear provisions in your country/region, it shall be implemented with reference to internationally accepted legal principles of privacy and data security;

2. Any dispute arising between you and the developer due to this Privacy Policy shall first be resolved through friendly negotiation; If negotiation fails, either party has the right to submit the dispute to an internationally recognized dispute resolution institution for arbitration, or file a lawsuit with a court having jurisdiction in your country/region.

7.4 Independence of Clauses

If any clause of this Privacy Policy is deemed invalid, revocable, or unenforceable by a competent authority, it shall not affect the validity, revocability, and enforceability of other clauses, which shall remain valid and binding on both parties.

7.5 Final Interpretation Right

The final interpretation right of this Privacy Policy shall belong to ICWorkshop Technology (Shenzhen) Co., Ltd. The interpretation content shall not violate relevant laws and regulations and the core formulation principles of this Policy, and shall be interpreted in accordance with the principle of "conducive to the protection of users' privacy".

ICWorkshop Technology (Shenzhen) Co., Ltd.

April 01, 2026