China Addendum Privacy Policy

Last Updated: July 2025

This China Privacy Policy (“China Notice”) supplements the information contained in the Goodnotes Privacy Policy and applies to residents of the People’s Republic of China (“China”, which for the purposes of this China Notice only shall exclude Hong Kong, Macau, and Taiwan). This China Notice is meant to cover the requirements under the Personal Information Protection Law (the “PIPL”) and other applicable laws and regulations in China.

Our subsidiary in China, GoodNotes Technology Development (Shenzhen) Co., Ltd./畅写科技发展(深圳)有限公司 (registered office at 5H8, Xinlikang Building, No. 3044 Xinghai Avenue, Nanshan Street, Qianhai Shenzhen-Hong Kong Cooperation Zone, Shenzhen, Guangdong Province, China) collect and process data and information from you during your interaction with us.

If any provision in this China Notice is inconsistent with any provision in our Privacy Policy, then this China Notice shall prevail to the extent on the processing of Personal Information of residents in China.

  1. 1. Information We Collect

    1. When we use the term “Personal Information” in this China Notice, we are referring to all kinds of information related to identified or identifiable natural persons recorded by electronic or other means, excluding the anonymized information, as defined under the PIPL. When we use the term of “Sensitive Personal Information” in this China Notice, we are referring to Personal Information that, if leaked or if used illegally, is likely to cause harm to a natural person's personal dignity or endanger his or her personal safety or the safety of his or her property, including biometric identification, religious belief, specific identity, medical health, financial account, whereabouts and tracks, as well as the personal information of minors under the age of 14, as defined under the PIPL.
    2. For more details about the specific data points we may collect, please see the “What kind of data is being collected and how do we collect” section in our Privacy Policy.
  2. 2. Children Under the Age of 14

    1. The Services are not directed to children under the age of 14, and we do not knowingly collect Personal Information from children under the age of 14.
    2. If we are notified that we have collected or received Personal Information from a child under 14, we will take steps to delete such information as soon as possible. If you are a parent or legal guardian and believe that your child has provided us with Personal Information, please contact us at legal@goodnotesapp.com .
  3. 3. What is your information being used for?

    1. We collect and process your Personal Information, including Sensitive Personal Information, only for specified, explicit and reasonable purposes and to the extent directly relevant to the purposes of processing, as set out in our Privacy Policy and in this China Notice.
    2. For the purposes and scenarios that we may process your Personal Information, in addition to those listed in “What is this data being used for” section in our Privacy Policy, the following situations are also applicable in China:
      • your Personal Information has been made public by you or has otherwise been lawfully made public, the processing is done pursuant to the PIPL and the extent the processing is reasonable; and
      • the processing is done in other circumstances provided for in applicable laws or regulations.
  4. 4. Who is your information disclosed to?

    1. As set out in below, we will share your Personal Information with third parties such as such as suppliers and vendors. We list in below to inform you the name and contact details of the third parties, the types of personal information to be shared, and the purposes and means of processing and sharing the personal information. We will also obtain your prior consent to the sharing of Personal Information where required by applicable law.
    2. Name of the Third Party Name/Type of the Third Parties’ Services Types of Personal Information Shared with by Third Parties Purpose for Sharing Sharing Method Link to the third parties’ privacy policy or related legal documents
      Amazon Web Services (AWS) China Cloud Infrastructure Provider
      • Any information/selections that you choose to upload or share through the Services or that you choose to tell us or a Goodnotes staff member.
      • Information that we automatically collect or generate about you.
      • Personal identifiers and contact information.
      To provide the underlying cloud computing and storage infrastructure necessary to operate the Goodnotes application and its features. Our application and services are hosted and run on the AWS China cloud platform. Future data storage will occur within their secure S3 and RDS services. View Policy
      Aliyun Cloud and Artificial Intelligence (AI) Service Provider
      • Any information/selections that you choose to upload or share through the Services or that you choose to tell us or a Goodnotes staff member.
      • Information that we automatically collect or generate about you.
      To enable our AI features, we may share your prompts, notebooks, documents, or other data necessary for the AI function with Aliyun's Bailian platform for Large Language Models (LLM) to provide users with advanced AI-powered features within the Goodnotes application. Secure Application Programming Interface (API) calls are made from our platform to Aliyun's service. We receive the processed results to display the AI-generated content to you. View Policy
      21Vianet (Microsoft Azure China) Cloud and Artificial Intelligence (AI) Service Provider
      • Any information/selections that you choose to upload or share through the Services or that you choose to tell us or a Goodnotes staff member.
      • Information that we automatically collect or generate about you.
      To offer users features such as document analysis and audio transcription within the Goodnotes application. In providing these features, we will utilize Azure's Document Intelligence and Speech Services. The personal information shared will be limited to documents, notebooks, and audio files you select for analysis or transcription. Secure Application Programming Interface (API) calls are made from our platform to the Azure services operated by 21Vianet in China. View Policy
    3. For more details about the specific data we may share, please see the “Who is my data disclosed to” section in our Privacy Policy.
  5. 5. Your Rights and Choices under the PIPL

    1. You have the following rights provided according to the PIPL, relevant regulations and other standards in China:
      • Right to Access, Copy and Correct Your Personal Information: You have the right to access, copy and correct your Personal Information, unless otherwise provided by laws and regulations.
      • Right to Erase Your Personal Information: You have the right to request the deletion of your Personal Information under the following circumstances:
        1. if our processing of your Personal Information is in violation of applicable laws or regulations;
        2. if we collect or use your Personal Information without obtaining your consent;
        3. if our processing of your Personal Information breaches any agreement entered into with you;
        4. if you no longer use our Services, or have deactivated your account; and
        5. if we no longer provide Services to you.
      • We will also notify any third parties that may have obtained your Personal Information from us and instruct them to delete such information in a timely manner, unless otherwise provided by laws or regulations, or if those third parties have obtained your separate authorization.
      • Please note that when you delete information from our Services, we may not immediately remove the corresponding data from our backup systems, but we will delete such information upon the update of those backups.
      • Right to Change or Withdraw Consent: Each core function may require a certain amount of your basic Personal Information to be performed. For the collection and use of your additional Personal Information, you may grant or withdraw your consent at any time, which may affect your use of the Services.
      • Right to Deactivate Your Account: You may deactivate your registered account at any time. After account deactivation, we will cease to provide you the Services and, upon your request, delete your Personal Information unless otherwise required by laws or regulations.
      If you would like to exercise your rights, or if you have any question about this China Notice or how we use your Personal Information, you may refer to our Privacy Policy or contact us at legal@goodnotesapp.com. To ensure security, we may ask you to complete identity verification before we process your request. Generally, we will respond within 15 working days after verifying your identity.
  6. 6. Retention Process

    1. We retain your personal data only for as long as necessary to fulfill the purposes outlined in our Privacy Policy and this China Notice, unless a longer retention period is required or permitted by law. After exceeding this period, we will delete, anonymize, or securely store your Personal Information until deletion is possible.
    2. If we cease operations, we will promptly cease the activities of collecting your Personal Information, and we will delete or anonymize your Personal Information held by us.
  7. 7. International transfers of Personal Information

    1. In principle, we store your Personal Information within China. Under certain circumstances, we may transfer your Personal Information outside of China. If so, we will fulfil our obligations under applicable laws and regulations.
    2. If we transfer your Personal Information to any recipient that is based outside of China, we will obtain your prior separate consent before transferring such Personal Information if consent is chosen as the lawful basis. In addition, we will ensure that your Personal Information is protected to a degree no less than that stipulated in this China Notice through contractual arrangements.
  8. 8. Changes to this China Notice

    The Company reserves the right to make changes to this China Notice at any time by giving notice to its users on the site, the Goodnotes application, or as notified by us to you (by email for example), where possible. We recommend checking this page to stay up to date with the latest changes.