Updated on November 17, 2021
- Collection of Personal Information
- Data Processing
- Sharing, Transfer and Disclosure of Personal Information
- Retention Period for Personal Information
- Protection of Children’s Personal Information
- Personal Information Protection Measures
- Personal Information Storage
- Cross-border Transfer of Personal Information
- Cookies and Other Technologies
- Personal Information Right and Its Exercising
- Contact Us
1 Collection of Personal Information
1.1 Definition of Personal Information
1.2 Ways to Collect Personal Information
We will collect your personal information when you:
- register as our user;
- sign up or participate in our activities;
1.3 Contents of Information Collected
We will collect your personal information as required by laws and regulations and abide by the principles of reasonableness and necessity. In other words, we will try to collect only the data we need. The contents of information to be collected depend on how you interact with us, including:
- the information of your email, name, password, company, website, position, phone number, region, country, or city that you provide when you register or log in our website;
- other information you provide us with your express consent.
2 Data Processing
2.1 Our Role
We are the Controller of your personal data.
2.2 Legal Basis
We will abide by the applicable laws and process your data based on the appropriate legal basis, including:
- Your express consent.
- Fulfillment of the contract entered into with you.
- Data processing necessary to protect the vital interests of you or other natural persons. For example, to ensure information security or to prevent fraud.
- Data processing based on our legitimate rights and interests. For example, to achieve marketing purposes, implement company policies, manage daily affairs, use data in an aggregated manner for data analysis, and transfer data to other departments of our company.
- Fulfillment of legal obligations or performance of duties involving the public interests.
2.3 Right Not to Provide Personal Information
You have the right to choose not to provide the personal data we request from you. However, if you choose not to provide it, in many cases we may not be able to provide our products or services to you or respond to your requests in accordance with the Terms of Service.
2.4 Purposes and Manners
We will use your information for the following purposes and in the following ways:
- To verify your identity to prevent unauthorized access;
- To provide you with our services and products in accordance with the contract we have signed with you;
- To provide other services requested by you in accordance with the requirements stated when we collected the information;
- To share your information with our authorized partners so that they can assist us in providing you with our services and products;
- To process transactions and communicate with you regarding the status of those transactions.
- To help track and correct errors and malfunctions in the process;
- To share with our affiliates worldwide for internal administration and back-office support purposes, as necessary to perform the functions of the service;
- To detect and investigate information leakage, illegal activities, and fraud;
- To maintain the integrity and security of our information systems that store and process your personal information;
- To carry out internal audits and data analysis and research for analyzing the efficiency of business operations and further improve our services.
- To comply with applicable laws and regulations, and cooperate with legal proceedings, litigation, or government authorities to provide relevant information.
3 Sharing, Transfer and Disclosure of Personal Information
Your personal information will be kept strictly confidential, and we will not share your personal information with any other companies, organizations, or individuals, except in the following cases:
- We will share your personal information with other parties with your express consent.
- We will share your personal information with our third-party service providers (or partners) to assist us in providing or improving our services, including, but not limited to, cloud services, video surveillance services, technical supports for information systems, and providing customer services. We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and only to the extent necessary to provide the services. Our third-party service providers (or partners) are not authorized to use the personal information shared for any other purpose. We will sign strict Data Processing Agreement with all third-party service providers (or partners) involved, and require them to take certain security measures to handle your personal information in accordance with relevant laws and regulations and our requirements to safeguard your personal information.
We will not transfer your personal information to any company, organization or individual except the following circumstances:
- When we obtain your express consent;
3.3 Public Disclosure
We will only publicly disclose your personal information under the following circumstances:
- When we obtain your express consent or based on your active choice;
- When we are required to disclose your personal information by laws and regulations or compulsory requirements of government authorities. If we receive any judicial or other documents such as government subpoenas, search warrants or orders, we will report these to our data protection office immediately for review and then reply to the relevant departments. If it is deemed that the relevant department has jurisdiction after review and no other law prohibits us from doing so, we will disclose the relevant information to the judicial or government as expressly required by the order or guarantee.
In accordance with relevant laws and regulations, we can share, transfer, and publicly disclose your personal information without your consent under the circumstances:
- related to national security and national defense security;
- related to public safety, public health, and due to major public interests;
- related to criminal investigation, prosecution, trial or execution of judgments;
- in which the disclosure of personal information is necessary to protect your or other individuals’ major legal rights and interests such as life and property but it is very difficult to obtain your consent;
- in which you have disclosed to the public the personal information by yourself;
- when the information is legally collected from publicly disclosed information, such as legal news reports, government data, or other channels.
4 Storage Period for Personal Information
We store personal information in conformity with applicable laws. After collecting personal information, we will stop gathering personal data, or delete sensitive and identification information. If it for public interest, scientific and historical research or statistic purpose, we will continue to retain relevant data in conformity with applicable laws, even if it would be not relevant to the original collection purpose.
5 Protection of Children’s Personal Information
Our services are mainly for adults, and we have taken additional procedures and measures to ensure the security of children’s personal data. We consider minors under 14 years of age (or the age required by local law) as children.
We will use or disclose children’s personal data as permitted by law, with the consent of parents or guardians or for the purpose of protecting children. We will try to delete the relevant data as soon as possible if it is found that we have collected personal information of minors without the prior consent of a verifiable guardian.
6 Personal Information Protection Measures
We abide by the recognized key data protection principles (fairness, purpose limitation, data quality, data retention, compliance with personal rights and security), and take reasonable measures to ensure the security of your personal information. We have applied a series of technical measures to protect the security of your personal information and minimize the risk of misuse, unauthorized access and disclosure and inaccessibility. The security measures we use include but are not limited to data desensitization, data encryption, firewall and data access authorization control.
At present, we have obtained the following professional certification:
- ISO 27001 Information Security Management System Certification
Meanwhile, we inspect and update the security mechanisms for data protection periodically to provide effective protection in preventing data abuse. If you believe that the security of your data has been compromised, or if you want to know more about the measures we use to protect your data, you can send an email to email@example.com to contact our data protection office.
7 Cross-border Transfer of Personal Information
As a multinational company, our data processing team may be located anywhere within our business scope, so its scope of responsibility may cover the whole world or multiple countries/regions, including countries outside the European Union. The personal information protection standards adopted by these countries/regions may be different from the standards used in your country.
8 Cookies and Other Technologies
We and the third-party service providers use technologies such as cookies, tags, and scripts, which help us better understand user behavior (including for security and anti-fraud purposes) and tell us which parts of our website users have viewed. They can also measure and improve the effectiveness of advertising and web searches.
- Strictly necessary cookies: These cookies must be set in order to provide specific functions or services that you access or request. For example, we need to use them to display the website in an appropriate format and language.
- Other cookies: We use these cookies to understand how visitors interact with our website and online services, helping us evaluate the effectiveness of advertising and web searches. We also use these cookies to remember the choices you make while browsing in order to provide you with a customized experience.
If you do not want to use these cookies, you can consult the browser vendor you are using to learn how to disable cookies. But if you disable all cookies, some features of our website will become unavailable.
9 Personal Information Rights and Its Exercising
9.1 Personal Information Rights
- Right of Access: The right to require us to provide a copy of your personal information we hold.
- Right of Correction: The right to require us to correct the information if it is incorrect or out of date.
- Rights of Cancellation and Deletion: We will regularly back up data to prevent data loss caused by server failure or human error. You have the right to require us to cancel your account or delete your personal information we hold at any time.
- Portability: The right to require us to provide you with your data and, if possible, transmit the data directly to other data controllers.
- Right to Restrict Processing: If you have any dispute about the accuracy or legality of our processing of your personal information, you have the right to require us to restrict processing; however, your right to restrict processing may cause you to be unable to use our services normally.
- Right to Object: The right to oppose our use of your personal information for user related and automatic decision-making, that is, the right to oppose our use of your personal information to send commercial information for marketing.
- File a Complaint: The right to file a complaint to the competent authorities of your place of residence or member states about our processing of your data.
- Consent Withdrawal: The right to withdraw your consent to our use of your personal data, including the collection, use and/or disclosure of your personal information that we hold or control by submitting a request. Please note that this may prevent you from enjoying some or all of our products or services, which depends on the scope of information you authorize us to process.
9.2 Ways to Exercise Personal Information Rights
We protect your rights to access and correct your personal information. If you want to exercise any of the rights specified in Section 10.1, please contact us via e-mail address firstname.lastname@example.org.
We will process your request on personal information within the time specified in applicable data protection law once we verify your identity and obtain sufficient information. However, please understand that we will not respond to your email if we hold that it is irrelevant to a personal information request.
9.3 Request Result
Several results may follow the request of a personal information subject:
(1) The request is rejected.
The request made by personal information subject will be rejected in cases including, but not limited to:
- Local law does not grant the personal information subject relevant rights;
- The identity of the subject cannot be verified;
- The request made by the personal information subject cannot be verified or is beyond the scope of personal information, especially when the request is repeated;
- The information is involved in compensation to be made or obtained in dispute and the information disclosure is likely to damage the interests of the relevant party;
- The information is retained only for statistical and research purposes and the republication of statistics and research result will not disclose personal information;
- Other cases stipulated in law.
We will offer an official explanation for the rejection of the request made by personal information subject.
(2) The request is approved.
We will approve the request made by personal information subject when the cases in (1) do not occur. In order to increase the likelihood of approval, please provide as much detailed information as possible when making a request, including the category and specific content of the request, relevant information of personal information holder (such as the name of the product and service you use), the time range of information generation and processing (the more accurate the time range, the greater the likelihood of approval).
9.4 Consent Withdrawal
You can change the scope of the information to be collected or withdraw your authorization by deleting configuration information and related devices and cancelling account. Please understand that business functions require basic personal information (such as registering your email address). We cannot continue providing you with the correspondent service and processing your personal information once you withdraw your approval or authorization. However, the decision of approval or authorization withdrawal will not affect the personal information processing based on your previous authorization.
- A major change in our service mode, such as the purpose for personal information processing, type of personal information to be processed and ways to use personal information.
- A major change in ownership structure and organizational structure such as ownership change caused by business adjustment, bankruptcy, merger or acquisition.
- A change in the major objects whose personal information will be publicly disclosed.
- A change in your rights to participate in processing personal information and the ways to exercise your rights.
- A change in the department responsible for personal information security, its contact information and complaint methods;
- Personal information security where an assessment report indicates that there is a high risk.
11 Contact Us