[Our Company] Privacy
Policy
Last updated: June 10,
2019
This Policy
applies to your use of the services provided by [Our
Company] and its affiliates
(hereinafter collectively referred to as "[WE]").
[Our Company] Privacy Policy as follows to define the type and manner of
personal information collected, used and shared with respect to each business
function of our products / services; to strengthen notification (e.g. by using
bold or popping up for the first use), inform users by immediate prompt and
offer users express options (initiative in checking) and inform users how to
revoke authorization immediately; to further define the manner of users'
inquiry about and correction and deletion of their personal information; to add
a cancelation function to user accounts; and to define the scenarios of
cross-border transmission, data receivers and protective measures of personal
information.
If you have
any question, advice or suggestion, please contact us in the following manner contact
page. [WE] has always attached great importance to the protection of customers'
personal information. Before you use [WE]'s services, be sure to carefully read and understand this
Policy, especially the clauses in bold. When you use [WE]'s services, or continue to use [WE]'s services after update of this Policy,
you will be deemed to have read, understood and consented to this Policy and
its updated version, and have agreed that we may process your personal
information according to this Policy. If you don't agree to any clause of this
Policy, you shall immediately stop using [WE]'s services.
We
collect information to provide better services to all our users
from
figuring out basic stuff like which language you speak, to more complex things
like which ads you'll find most useful, the people who matter most to you
online,
or
which videos you might like. The information [WE] collects, and how that
information is used, depends on how you use our services and how you manage
your privacy controls.
When you're not signed
in to a [WE] Account, we store the information we collect with unique
identifiers tied to the browser, application, or device you're using.
This helps us do
things like maintain your language preferences across browsing sessions.
When you're signed in,
we also collect information that we store the information.
About Things you create or provide to
us
When you create a [WE] Account, you provide
us with personal information that includes your name and a password. You can
also choose to add a phone number or payment information to your account. Even
if you aren't signed in to a [WE] Account, you might choose to provide us with
information like an email address to receive updates about our services.
We also collect the content you create,
upload, or receive from others when using our services. This includes things
like email you write and receive, photos and videos you save, docs and
spreadsheets you create, and comments you make on videos.
We collect information about the apps,
browsers, and devices you use to access [WE] services, which helps us provide
features like automatic product updates and dimming your screen if your battery
runs low. The information we collect includes unique identifiers, browser type
and settings, device type and settings, operating system, mobile network
information including carrier name and phone number, and application version
number.
We also collect information about the
interaction of your apps, browsers, and devices with our services, including IP
address, crash reports, system activity, and the date, time, and referrer URL
of your request.
We collect this information when a [WE]
service on your device contacts our servers for example, when you install an
app from the Play Store or when a service checks for automatic updates. If you're using an Android device with [WE]
apps, your device periodically contacts [WE] servers to provide information
about your device and connection to our services. This information includes things like your
device type, carrier name, crash reports, and which apps you've installed.
We collect this Your location information
We collect information about your location
when you use our services, which helps us offer features like near you. Your
location can be determined with varying degrees of accuracy by: GPS, IP address,
Sensor data from your device, Information about things near your device, such
as Wi-Fi access points, cell towers, and Bluetooth-enabled devices the types of
location data we collect depend in part on your device and account settings.
About collect and use your personal information
Personal
information means all kinds of information that is recorded electronically or
otherwise and can be used independently or in combination with other
information to identify a specific natural person's identity or reflect a
specific natural person's activity.
In some circumstances, [WE] also collects
information about you from publicly accessible sources. For example, if your
name appears in your local newspaper, [WE]'s may index that article and display
it to other people if they search for your name. We may also collect
information about you from trusted partners, such as directory services who
provide us with business information to be displayed on [WE]'s services,
marketing partners who provide us with information about potential customers of
our business services, and security partners who provide us with information to
protect against abuse. We also receive information from advertisers to provide
advertising and research services on their behalf.
Sensitive personal
information means any personal information that is likely to harm personal and
property safety and is very apt to cause damage or discriminative treatment to
any personal reputation, physical and mental health once it is divulged,
provided illegally or abused. Any sensitive personal information involved
herein will be highlighted in bold.
[WE] will collect and
use your personal information for the following purposes set forth herein only:
(i)
Collect and use your personal information for core business functions
We
may collect, store and use the following information related to you so that we
can realize the following functions. If you don't provide relevant information,
you will not be entitled to [WE]'s relevant services. These functions include:
1.
Account registration
In order to complete
creating an account, you shall provide the following information (hereinafter
collectively referred to as "Account Information"): your mobile phone number,
account name/ nickname and account password, and we will verify the validity of
your identity by sending a verification code through SMS; you may also provide
additional information on your birthday, gender and region, which will be
helpful for us to offer you a personalized service experience, and if you don't
provide such additional information, the basic functions of your use of [WE]'s
services will not be affected.
2.
Provide you with services
When you place a order
or your information is provided as receiver information, [WE] or its authorized
business partner will collect your following information: names, addresses and
contact information of the shipper and the receiver and shipment information
(hereinafter collectively referred to as "Waybill Information"), so as to
submit an order, generate a logistics waybill, pick up, sort out, store and
transport the shipment, conduct export or import customs clearance, and deliver
the shipment; according to relevant legal requirements, we will also collect
your identity card information to verify your identity and conduct export or
import customs declaration.
3.
Payment settlement
When you place an
order, you may choose the payment services provided by [WE]'s related party or
any third party payment organization cooperating with [WE] (e.g. [WE]
Financial, Alipay, WeChat Pay, Unionpay, NetsUnion, hereinafter referred to as
"Payment Institutions"), and we will provide your [WE] order number and
transaction amount information to these Payment Institutions to confirm your
payment instruction and complete payment. If you apply for an invoice, you
shall also provide the following information: invoice title, taxpayer ID,
recipient's email address, and more information provided according to your
invoicing demand such as buyer's information.
4.
Send messages
We will collect your
device information so that we can send you shipment routing, payment status,
coupons and sales promotions. You may enable "Do Not Disturb" in "Settings" on
your mobile phone or other devices or in APP or the official WeChat official
account.
5.
Customer service and after-sale service
Our customer service
and after-sale service representatives will use your Account Information and
Waybill Information. In order to guarantee your account safety, our call centre
and online customer service representatives will use your Account Information
to verify your identity. When you need us to provide any customer service and
after-sale service with respect to your shipment, we will ask for your Waybill
Information and shipment routing information. You may also be asked to provide
any information other than the said information when you communicate with our
customer service personnel, for example, when you require us to change the
delivery address, contact person or contact phone number. In addition, we will
also collect information from your answers submitted when you participate in
our questionnaire survey, and the contact person's name, company name, contact
phone number, email address and your inquiry information submitted by you in
"Cooperation Inquiry" on the official website of [WE].
6.
Improve our products or services
With respect to your
Account Information and Order Information, Waybill Information collected by us,
we may conduct data analysis to form a user portrait so as to provide you with
personalized services and send information on commodities or services you may
be interested in. With respect to the information collected from different
devices of yours, we may synchronize such information so that we can provide
you with consistent services on these devices. We may combine information from
certain services with information from other services, information accessed
lawfully and indirectly and information accessed through a lawful and public
channel, or combine your identifiable personal information accessed lawfully
with information failing to identify a person, so as to provide you with
personalized services and improve our products and services.
7.
Guarantee transaction safety
In order to improve the safety of the system
when you use our services, prevent any phishing site's fraud more accurately
and protect the account safety, we may judge your account risk by accessing
your browse information, order information , Waybill Information and common
software information and device information, and may record some links ("URL")
deemed to be risky by us; we will also collect your device information to analyse
[WE]'s system problem, count flow, check possible risks and check abnormal
information you choose to send us.
(ii) Collect and use
your personal information for additional business functions
In
order to enable you to use [WE]'s services more conveniently, we may collect
and use your personal information for the following additional functions. If
you don't provide such information, you may still use [WE]'s services, but you
may become unable to use these additional functions that may bring you
convenience or shall fill in some information repeatedly. These additional
functions include the following:
1.
Speech input
You may directly use a
microphone for speech input of Waybill Information or for consultation and
interaction with our customer service robot. In these functions, we will
collect your audio recording content to identify your shipment demand and
customer service and after-sale service demand.
2.
Map function
You may use this
function to inquire about [WE]'s service points and use our navigation
function. If you use this function, we need to collect your geographical
location information.
3.
Additional function based on a webcam (camera)
You may use this
additional function to complete shipping or paying by scanning a QR code.
4.
Additional function based on address book information
You
may choose to invoke your address book information so that you don't have to
manually enter the information on any contact person in your address book when
you fill in Waybill Information.
The
said additional function may require you to allow us to have access to your
geographical location (location information), camera (webcam), photo album
(photo gallery), microphone and address book in your device, so that we can
collect and use the information related to these functions. You may view the
opening status of the said authority in "Settings" on your mobile phone or
other devices and may decide to open or close such authority at any time. By
opening such authority, you authorize us to collect and use the said personal
information to realize the above functions; if you close such authority, we
will cease to collect and use the said personal information and will not be
able to provide the said functions corresponding to such authority. When you
close such authority, the previous processing of personal information based on
your authorization will not be affected.
(iii) Access and use
personal information indirectly
We
may access your Account Information (head portrait and nickname) from a third
party when you authorize such information to be shared, and will bind your
third party account with your [WE] account after your consent to this Policy,
so that you can directly log in and use [WE]'s services through such third
party account.
If you place a order
through a third party channel on any
page other than [WE]'s page, [WE] will access your Order Information from such
third party channel, including the names, phone numbers and addresses of the
shipper and the receiver and the shipment information, so as to provide you
with pickup and delivery services.
If we access your
personal information from our partner, after confirmation of the lawfulness of
the source of such personal information according to the agreement with the
third party, we will use such personal information subject to relevant laws and
regulations.
(iv) Other purposes
1.
[WE] may, by email, SMS or otherwise, send advertisements and
other commercial information [WE] deems you may be interested in.
2.
We will de-identify your personal information through technical
means and the de-identified information will not be able to identify a person.
You know and agree that we are entitled to use the de-identified information.
We are entitled to analyze and commercially use the user database on condition
that we will not disclose your personal information.
3.
We will prepare statistics on the use of our services and may
share such statistical information with the public or any third party to show
the general trend of use of our services. However, such statistical information
shall not include any of your personally identifiable information.
4.
When we show your personal information, we will desensitize your
information by replacing contents or through anonymous processing so as to protect
your information security.
5.
When we want to use your personal information for any other
purpose not set forth herein or use any information collected based on a
specific purpose for any other purpose, we will seek your prior consent by
clicking authorization online or by email or SMS.
(v) Exceptions when
consent is obtained
You
are fully aware that we are not required to seek your authorization or consent
when we collect and use your personal information in the following
circumstances:
1.
Such collecting and use are related to national security and
national defense security;
2.
Such collecting and use are related to public security, public
health and major public interest;
3.
Such collecting and use are related to criminal investigation,
prosecution, judgment and judgment enforcement;
4.
Such collecting and use aim to protect the life, property and
other major lawful rights and interests of personal information subjects or
other individuals but it is very difficult to obtain the consent of the owner
of the said information;
5.
The personal information collected is publicized by the personal
information subject to the public;
6.
Your personal information is collected from any information
disclosed lawfully and publicly such as lawful news reporting and government
information publicity;
7.
Such collecting and use are necessary for signature and
performance of a contract according to your requirements;
8.
Such collecting and use are necessary for maintaining the safe
and stable operation of the services provided, for example, discover and handle
service malfunctions;
9.
Such collecting and use are necessary for lawful news reporting;
10.
Any other circumstance provided by laws and regulations.
According to legal
provisions, if de-identified personal information is shared or transferred and
it is guaranteed that data receivers will not be able to recover such personal
information and re-identify personal information subjects, such sharing or
transfer is not sharing, transfer or public disclosure of personal information
to the outside, and storing and processing such data are not subject to further
notification to you and your consent.
About Cookie and
similar technologies
(i) Cookie
In
order to ensure the normal operation of the website, we will store a small data
file named Cookie in your computer or mobile device. A Cookie generally
includes an identifier, a site name and some numbers and characters. With the
help of the Cookie, the website will be able to store your preference data.
We
will not use the Cookie for any purpose other than the purpose set forth
herein. You may manage or delete the Cookie according to your own preference.
Refer to AboutCookies.org for details. You may remove all the Cookies stored in
your computer and most web browsers have the function of preventing Cookies.
However, if you do so, you need to personally change user settings each time
when you visit our website. If you need to understand in detail how to change
the settings of the browser, please visit the settings page of the browser you
use.
(ii) Website beacon
and pixel labels
In
addition to Cookies, we will also use website beacon and pixel labels and other
similar technologies on the website. For example, an email sent by us to you
may include a URL link to our website content. If you click such link, we will
track this click to help us understand your product or service preference and
improve customer service. A website beacon is generally a transparent image
embedded into the website or an email. With the help of the pixel label in an
email, we can know whether if such email is opened. If you don't wish your
activity to be tracked in this way, you may unsubscribe in our mailing list at
any time.
(iii) Do Not Track
Many
web browsers have the "Do Not Track" function, which can send a "Do Not Track"
request to the website. At present, major internet standard organizations have
not established the policy on a website's response to such request. However, if
your browser has enabled "Do Not Track", all of our websites will respect your
choice.
(IV) Other
We use various technologies to collect and
store information, including cookies, pixel tags, local storage, such as
browser web storage or application data caches, databases, and server logs.
About your information
share, transfer and publicly disclose
(i)
Sharing
1.
We will not share your personal information with any company, organization or
individual other than [WE] except in the following circumstances:
(1)
Sharing when your express consent is obtained: After your
express consent is obtained, we will share your personal information with
another party;
(2)
We may share your personal information with the outside
according to laws and regulations or the competent government department's
compulsory requirements;
(3)
It is necessary to provide your personal information in order to
protect the interests, property or security of [WE] or its partners, you or
other [WE] users or the public from being damaged to the extent permitted by
laws and regulations;
(4)
Only if your personal information is shared can we realize the
core functions of our services or provide the services required by you;
(5)
We handle your controversy or dispute with others at your
request;
(6)
We provide your personal information in compliance with any
relevant agreement (including any electronic agreement signed online) or other
legal document signed with you;
(7)
We use your personal information based on academic research;
(8)
We use your personal information based on public interest in
compliance with laws and regulations.
2. Sharing with our
affiliates: Your personal information may be shared with [WE]'s affiliates. We
will only share necessary personal information and will be bound by the
purposes stated herein. If any affiliate wants to change the processing purpose
of your personal information, it will seek your authorization or consent again.
Our
affiliates mean any entity that from time to time controls, is controlled by or
under common control with [WE]. or its entity. "Control" means direct or
indirect ownership or control of more than 50% of voting rights.
3. Sharing with
authorized partners: Some of our services will be provided by our authorized
partners only to realize the purposes stated in this Policy. We may share some
of your personal information with our partners to provide better customer
service and user experience. For example, when we provide you with customs
clearance services, we may share your personal information with customs
clearance service providers so as to arrange for our partners to provide
services. We will only share personal information necessary for provision of
services and our partners have no right to use such shared personal information
for any other purpose.
At
present, our authorized partners include the following types:
1)
Suppliers, service providers and other partners. We will send information to
suppliers, service providers and other partners who support our business in the
whole world, and such support includes providing infrastructure services,
analyzing the use manner and potential risk of our services, providing
advertising services, transportation, warehousing, customs clearance, terminal
pickup and delivery, payment convenience, customer service, data storage
services and third-party additional business function services (e.g. speech
input and map function) or conducting academic research and investigation.
We
and our affiliates shall be governed by the same data compliance management
system, this Policy and relevant confidentiality and security measures. If we
share personal information with companies, organizations and individuals other
than our affiliates, we will sign a strict confidentiality agreement / data
processing agreement with such companies, organizations and individuals,
requiring them to process such personal information according to our
explanations, this Policy and any other relevant confidentiality and security
measures.
(ii) Transfer
We
will not transfer your personal information to any company, organization or
individual except in the following circumstance:
1.
Transfer with your express consent: After your express consent
is obtained, we will transfer your personal information to another party;
2.
When any merger, acquisition or bankruptcy liquidation is
involved, we will require any new company or organization holding your personal
information to continue to be bound by this Policy in case of any transfer of
personal information; otherwise we will require such company or organization to
re-seek your authorization or consent.
3.
We provide your personal information in compliance with any
relevant agreement (including any electronic agreement signed online) or other
legal document signed with you;
4.
We provide your personal information according to applicable
laws and regulations, or the requirements of legal procedures, or compulsory
administrative or judicial requirements.
(iii) Public
disclosure
We
will publicly disclose your personal information only in the following
circumstances:
1.
After your express consent is obtained;
2.
Disclosure based on laws: We may publicly disclose your personal
information when laws, legal procedures, lawsuits or competent government
departments' compulsory requirements require so.
(IV) How is your
personal information transferred in the world
In
principle, the personal information collected and generated by us in a certain
country / region will be stored within such country / region.
By
choosing [WE]'s international shipment services, you are clearly aware that
your personal information will be transmitted to another country / region other
than the original collecting country / region. [WE]'s international shipment
services are based on self-operation or partners' agency and we will transmit
an international shipment's Waybill Information to our affiliate or partner in
another country / region other than the original collecting country / region
through system interconnection.
There
may be different data protection laws or no relevant laws in such country /
region. Under a similar circumstance, we will ensure that your personal
information will receive sufficiently equal protection as compared with the
original collecting country / region. For example, we will transmit Waybill
Information in an encryption manner, regularly assess and audit the receiver's
security capacity level and sign data processing agreements / clauses.
About your personal
information protect and store
(i)
How do we protect your personal information
1.
[WE] has established a data security management organization and
take security precautions for personal information in physical (entrance guard
isolation and monitoring system), management (establish an information security
system, classify and grade data, sign a non-disclosure agreement with
employees, organize data security and privacy protection training and regularly
conduct self-assessment of compliance) and technical (ensure transmission
encryption in the manner of safe browse of https, use AES256 encryption
technology to ensure data storage encryption, desensitization of sensitive
information display, anonymous processing, and equip the access to the system
with a dual-certification access control mechanism, automated code inspection
and log audit) aspects to protect your personal information from unauthorized
access, use, disclosure or revision, or damage or loss or any other form of
illegal processing.
2.
We will regularly organize a security contingency plan drill to
prevent a security incident from occurring. In case of an unfortunate security
incident, when [WE] is aware that the security of the data accessed and stored
by it is endangered or that a user's non-public information is disclosed to an
irrelevant third party due to any external act (e.g. hacker attack),
notwithstanding other disclaimer provisions herein, [WE] will initiate the
contingency plan, organize an emergency team, start procedures, conduct
internal investigation, report to the higher department, notify regulatory
authorities and cooperate with regulatory authorities to reduce the impact of
the accident on the user, and in a circumstance [WE] thinks fit, [WE] will
inform the user of the disclosed information and the extent of [WE]'s awareness
of such circumstance by sending a notice, email or announcement.
(ii) Storage period of
personal information
1.
Your Account Information and the information on rights,
interests and virtual assets in your account will be deleted thirty days after
you cancel your account, and you will have a pulling-back period of thirty
days; if you want to use the original account within thirty days, it is
sufficient to re-register it.
2.
In order to satisfy your inquiry need, your Waybill Information
will be reserved in [WE]'s foreground system for thirty days and you may
inquire about shipment routing information on the official website of [WE]
Express through the shipper indicated on the waybill, the receiver's mobile
phone number or the waybill number; after expiry of such period, we will remove
your Waybill Information from [WE]'s foreground system, so that such
information cannot be retrieved or accessed, or will conduct anonymous
processing.
3.
Your personal information will be stored in [WE]'s background
system for a longer period, which will be determined according to the type of
such personal information, the requirements of laws and regulations and the
compliance with the purpose set forth herein.
4.
If we terminate services or operation, we will give not less
than thirty days' notice to you and will delete your personal information or
conduct anonymous processing thereof after such termination.
About Your rights
According
to relevant Chinese laws, regulations and standards and the prevailing
practices of other countries and regions, we will guarantee that you can
exercise the following rights to your own personal information:
(i) Access your
personal information
You
are entitled to access your personal information unless any exception is
provided by laws and regulations. If you want to access your data, you may do
so in the following manner:
Account Information -
If you expect to access or edit your personal information in your account, you
may use your [WE] account and password to log in to [WE]'s relevant website,
APP or official WeChat account in which you have registered so as to inquire
about the personal information provided to [WE] at the time of your
registration.
Shipping record and
transaction record - You may use your [WE] account and password to log in to [WE]'s
relevant website, APP or official WeChat account in which you have registered
so as to view such information.
Shipper and receiver
information - You may use your [WE] account and password to log in to [WE]'s
relevant website, APP or official WeChat account in which you have registered so
as to add, revise or delete your shipper address and common receiver address
(some channels do not support such function).
If
you need to access other personal information generated during your use of our
products or services, you may contact us and we will respond to your request
according to the manner and period set forth herein.
(ii) Correct your
personal information
When
you discover any error with respect to your personal information processed by
us, you are entitled to require to make correction. You may correct your
personal information in the manner set forth in "(i) Access your personal
information".
If
you need to correct other personal information generated during your use of our
products or services (e.g. revise your delivery address and contact phone
number), you may contact our customer service department.
(iii) Delete your
personal information
In the following
circumstances, you may request us to delete your personal information:
1.
Our processing of your personal information is in violation of
laws and regulations;
2.
We collect and use your personal information without your
consent;
3.
Our processing of your personal information is in breach of the
agreement with you;
4.
You cease to use our products or services or you cancel your
account;
5.
We cease to provide you with products or services.
If we decide to
respond to your deletion request, we will also make every effort to notify any
entities receiving your personal information from us and require such entities
to delete your personal information in time unless laws and regulations
otherwise provide or such entities obtain your independent authorization.
When
you delete your information in our services, we may not immediately delete corresponding
information in our backup system, but we will delete such information when our
backup system is updated.
(iv) Change the scope
of your authorization and consent
Some
basic personal information is necessary for completion of each business
function (see "Part I" of this Policy). With respect to the collecting and use
of additional personal information collected, you may grant or withdraw your
authorization and consent at any time.
You
may change the scope of your authorizing us to continue collecting personal
information or withdraw your authorization by deleting information, closing
device function or conducting privacy setting or setting up or closing relevant
authority in your device on [WE]'s website, App or official WeChat account (see
"(ii) Collect and use your personal information for additional business
functions" in "Part I" of this Policy). You may also withdraw all of your
authorizing us to continue collecting your personal information by canceling
your account.
When
you withdraw your consent, we will cease to process corresponding personal
information. However, your decision to withdraw your consent will not affect
the previous processing of your personal information based on your
authorization.
If
you don't want to accept any commercial advertisement sent by us to you, you
may cancel it in the following manner at any time:
Whether
you refuse to accept relevant information based on any reason, when you receive
marketing information, you may require [WE] not to send you marketing
information according to the unsubscribing prompt in the information (e.g.
"Reply with TD to unsubscribe") and [WE] will respect your request.
(v) Personal
information subject's account cancelation
You
may log in to the "Our System" to submit an application for account cancelation
on the page of "Account Cancelation". Thirty days after account cancelation, we
will delete your account information unless laws and regulations otherwise
provide.
(vi) Respond to your
above request
In
order to guarantee security, you may need to submit a written request or
otherwise prove your identity. We may first require you to verify your own
identity and then process your request.
We
will give a reply within thirty days.
In
principle, we will not collect charges for your reasonable request, but we will
collect certain costs and charges depending on the circumstance in case of any
repeated request beyond a reasonable scope. We may refuse any request that is
repeated without cause or requires too many technical means (e.g. requiring
development of a new system or fundamental change of current practices) or
causes risks to others' lawful rights and interests or is very impracticable
(e.g. involving information stored on backup tapes).
In the following
circumstances, we will not be able to respond to your request according to the
requirements of laws and regulations:
1. Such request is
directly related to national security and national defense security;
2. Such request is
directly related to public security, public health and major public interest;
3. Such request is
directly related to criminal investigation, prosecution, judgment and judgment
enforcement;
4. There is sufficient
evidence that you have subjective malice or abuse your right;
5. Responding to your request
will cause your or other individuals' or organizations' lawful rights and
interests to be seriously damaged.
6. Such request involves
any trade secret.
About children's
personal information
Our
products, websites and services are mainly oriented toward adults. Children
shall not use our products or services without the consent of their parents or
guardians.
If
children's personal information is collected with the consent of their parents,
we will use or publicly disclose such information only to the extent permitted
by law, expressly approved by their parents or guardians or necessary for
protection of such children.
Notwithstanding
the difference in definitions of children according to local laws and customs,
we treat any person aged below 16 as a child.
If
we discover that we have collected children's personal information without the
demonstrable consent of their parents, we will seek to delete relevant data as
soon as practicable.
About Policy updated
Our
privacy policy may be changed.
We
will not reduce the rights to which you shall be entitled according to this
Policy without your express consent. We will release any change in this Policy
on this page.
In
case of any material change, we will provide a more conspicuous notice
(including for some services, we will give notice by email or SMS to explain
the specific changed contents of the Privacy Policy).
For the purpose
hereof, material change includes without limitation the following:
1.
Material change occurs to our service model. For example, the purpose of
processing personal information, the type of processed personal information,
and the manner of use of personal information;
2.
Material change occurs to our ownership structure or organizational structure.
For example, owners' change arising from business adjustment or bankruptcy
merger and acquisition;
3.
Change occurs to major subjects of sharing, transfer or public disclosure of
personal information;
4.
Material change occurs to your right to participate in the processing of personal
information and the manner of exercise of such right;
5.
Change occurs to our department responsible for handling the security of
personal information, our contact information and our complaint channel;
6.
A report on the security impact assessment of personal information shows that
there is high risk.
We
will also place the old version of this Policy on file for your consultation.
About contact us
If
you have any doubt, advice or suggestion about this Privacy Policy, you may
contact us in the following manner on contact page.
As
a general rule, we will reply within thirty days. If you are dissatisfied with
our reply, especially when our processing of personal information damages your
lawful rights and interests, you may also seek a solution through the following
external approach: You may complain or report to the regulatory authorities in
your country such as China's regulatory authorities in charge of network
information, telecommunication, public security as well as industry and
commerce.
