JINGDIGITAL Privacy Policy
Last updated: 1 November 2021
Shanghai Jingdigital Network Technology Co., LTD. (” We “or” JINGdigital “) thank you for your interest in our products and services. We attach great importance to your personal information and privacy, protecting your personal information is our important goal, at the same time, we believe that the information you provide can help us to provide you with better products and services. Therefore, we have developed this Privacy Policy (the “Policy”) to protect your personal information, and we want to explain to you how we collect, use, store and protect this information when you use our products and services, and how we provide you with access to, update, delete and protect this information. Please read this policy carefully and fully understand it before using our products or services.
This policy applies to the related products and services provided by JINGdigital for you, including various forms of JINGdigital’s service platforms containing such content, such as websites, mobile applications, wechat public platforms, mini programs, etc. (including new service forms arising from future technological development). Offline events, exhibitions and any other means of communicating with us (collectively referred to as the “Service Platform”). Please note that JINGdigital Service platform may contain links or directions to other websites, we have no control over these third party websites or apps, this policy does not in any case apply to other third party services provided to you, any non-Jingdigital products or services are not covered by this policy. If there is a written agreement between us and you that is inconsistent with this policy, our agreement with you shall prevail.
In order to use JINGdigital’s products or services, you should carefully read and abide by the entire contents of this policy, and start using it after confirming that you fully understand and agree, especially the terms involving exemptions or limitation of liability, which are highlighted in bold form. If you do not agree with any of the following, please stop accessing/using our service platform immediately; If you continue to access/use our service platform, it is deemed that you fully accept the entire content of this policy.
This policy will help you understand the following:
·How do we collect and use your Personal information
·How do we entrust, share, transfer and publicly disclose your personal information
·How do we use cookies and other recording tools
·How do we protect and store your personal information
·Your rights
·Third party service
·How do we handle minors’ personal information
·Dispute resolution
·Disclaimer on updates to this policy
·How to contact us
1 How do we collect and use your Personal information
1.1 The definition and scope of personal information
Personal information is information about identified or identifiable natural persons recorded electronically or by other means, excluding information that has been anonymized. The scope of personal information we may collect includes:
Personally identifiable information: including name, address, telephone number, email address, occupation, etc;
Sensitive personal information: including personal whereabouts and track information;
User profile information: Through the collection, aggregation and analysis of personal information, the personal characteristics of a certain natural person, such as their personal preferences, behaviors, etc. are analyzed or predicted to form their personal characteristics model;
Other personal information: information on mobile communication operators provided by relevant government agencies, information agencies and other legal information providers;
Other personal information obtained and saved during the establishment and maintenance of business or other relationships with you, such as call recordings, chat messages, service usage time, website/mobile application/platform/software browsing, use, click, operation log information, operating system version, etc.
If the personal information subject cannot be identified through technical processing and cannot be recovered after processing, the anonymized information does not belong to personal information. Other information that does not identify a specific natural person or reflect the activities of a specific natural person is not personal information.
If you provide personal information that is not your own, you have obtained the formal permission of another person and have informed that person how we will use their information. The information you provide about others also applies to this policy.
1.2 Collection and use of personal information
1.2.1
In general, you do not need to provide your personal information to access our websites and applications, but in order to provide you with services and improve the quality of services, we need or may need to collect and use your personal information. There are two main scenarios:
（1）In order to realize the basic functions of the services we provide to you, you must authorize us to collect and use the necessary information;
（2）In order to realize the additional functions of the services we provide to you, you can authorize the information we collect and use. This information is not necessary for the operation of the service, but it is very important to improve the quality of the service and develop new products or services.
1.2.2
In order to provide you with products or services, we will collect your personal information for the following purposes and circumstances:
（1）You are interested in obtaining marketing materials or learning about our products and services
When you want to know or apply for trial on our service platform, you need to provide us with the following information: name, mobile phone number, company name, company email address, job title, etc. We will verify the validity of your mobile phone number by sending an SMS verification code, and will also feedback your query results based on the information you provide, and contact you according to the mobile phone number you provide.
（2）Contact you
When you participate in our marketing or experience feedback, or when we partner with third parties, in order to facilitate contact with you, we will collect and record your mobile phone number based on your submission. If you refuse to provide the above information, we will not be able to follow up with you.
（3）Business data that you provide to us or entrust us to process
In the course of providing the services to you, you will provide or entrust us with the processing of business data necessary to fulfill your needs. You are responsible for the source and content of your business data, especially when such business data contains personal information, you should be careful to provide or entrust processing in accordance with laws and regulations and relevant provisions. All consequences and responsibilities caused by your business data content in violation of laws and regulations or relevant regulations shall be borne by you.
We will collect, process, store, transmit and provide such business data according to your instructions and authorization, and we will not use or disclose your business data without your consent except in accordance with your requirements or law enforcement situations in China.
If you need to provide the personal information of your employees, such as name, address, mobile phone number, position, email address, etc. for the purpose of helping you manage the organizational structure of your employees, you shall ensure that you have fulfilled the obligation of prior notification of the personal information subject, including the method, purpose and scope of personal information processing, and have obtained explicit authorization consent.
（4）Manage your account for you
To open some service functions that require you to complete the company’s real name authentication, you need to submit the company’s business license and other company documents, as well as the personal information of the legal representative and account administrator, such as name and mobile phone number; In order to achieve multi-level account use and management, you may also be required to provide your employees’ personal information through uploading and other means, such as communication information, business card information, etc; You shall obtain prior authorization and consent from the subject of such personal information, and ensure that the processing of the aforementioned personal information conforms to the authorized purpose, manner and scope. You understand and agree that we will access, manage and use our Services to process the data you provide in accordance with the instructions of your user administrator.
（5）Information provided to us by third parties
We will obtain your information from partners, affiliates or other third parties through legal means or information you entrust to process, such as through the mobile phone operator based on your personal mobile phone number to send SMS verification code.
（6）Log information
When you use our service platform, we will automatically collect details of your use of our service and save them as relevant web logs, such as the content of your search query, IP address, type of browser, telecom operator, language used, date and time of access, and records of the pages you visit.
Please note that individual equipment information, log information, etc. are information that cannot identify a natural person. If we combine such non-personal information with other information to identify natural persons, or use it with personal information, during the period of combined use, such information may be regarded as personal information, unless we have obtained your consent or unless otherwise required by law and regulations, we will anonymize such personal information.
（7）Software service packages provided by third-party service providers
In order to enable you to use our services and features, the application is embedded with an authorized partner’s SDK or other similar application. We will agree on strict data protection measures with authorized partners to process personal information in accordance with our purpose of authorization, service description, this policy and any other relevant confidentiality and security measures; Collect mobile phone identifiers for platform message push.
（8）Access to your device
The above functions may require access to your geographical location (location information), camera (camera), album (photo gallery), notification (information push) in your device to enable the collection and use of the information involved in these functions. For the specific access rights required for each function, please refer to the detailed description of these functions above; We collect only those categories of permissions necessary for the personal information mentioned in the specific description and will not request additional permissions beyond what is required for the function. You can check the status of the above permissions on your device through “Settings” (such as “Settings – Privacy” in iOS and “Settings – Application Permissions” in Android), and you can decide to turn these permissions on or off at any time. Please note that if you choose to open these rights, you expressly agree to authorize us to collect and use these personal information to achieve the above functions, if you close the rights, you cancel these authorizations, we will no longer collect and use your personal information, and we will not be able to provide you with the above functions corresponding to these authorizations. Your decision to close your rights will not affect the processing of personal information previously conducted on the basis of your authorization.
Please understand that the functions and services we provide to you are constantly updated and developed, if a function or service is not in the above description and collect your information, we will separately explain the content, scope and purpose of information collection to you through the page prompts, interactive processes, website announcements, signed agreements and other ways to obtain your authorization and consent.
We may need to use your information to process and resolve legal disputes, or to comply with any laws or regulations or documents issued by regulatory authorities that are binding on us, in order to cooperate with national authorities or regulatory authorities for the purpose of investigating and complying with laws and regulations.
1.3 Exceptions to the collection and use of personal information
When we collect and use your personal information, we will follow the principles of legality, legitimacy and necessity. In the following circumstances, we may not need to obtain your authorization for the collection and use of information:
· Necessary for the performance of statutory duties or obligations;
· Necessary for responding to public health emergencies or for protecting the life, health and property safety of natural persons in emergency situations;
· Conduct news reporting, public opinion supervision and other acts in the public interest, and process personal information within a reasonable scope;
· In accordance with laws and regulations, to process within a reasonable scope the personal information disclosed by an individual or other legally disclosed personal information;
· Other circumstances prescribed by laws and regulations.
2 Entrusted processing, sharing, transfer and public disclosure of personal information
2.1 entrusted handling
Some specific functions of our business functions may need to be provided by third-party suppliers, such as we need to provide SMS verification services through mobile operation providers, help you better analyze live broadcast data through live broadcast platforms, etc., the purpose of such information processing is limited to providing services to you. We will sign strict confidentiality agreements with companies, organizations or individuals that we entrust to process personal information, requiring them to process personal information in accordance with our requirements, personal information protection policies and any other relevant confidentiality and security measures.
2.2 Sharing
We will not actively share the information we obtain and collect with other companies, organizations and individuals or with third parties, except in the following circumstances:
· For the purpose of serving the operation of the platform or JINGdigital’s business services, according to your instructions or entrustment, to share the information on this website with your affiliated companies or designated third parties, including transferring the information to devices located in China or abroad, if it involves providing personal information abroad, we will comply with the requirements of laws and regulations.
· As required by law, regulation or policy, such as subpoenas, government questioning, litigation, dispute resolution or similar legal proceedings;
· When we believe in good faith that the disclosure is necessary to protect our rights, to protect your safety or the safety of others, or to meet the requirements of law enforcement;
· Share with our affiliates or relevant parties who have business cooperation with us for the purpose of promoting JINGdigital, business partners or both parties;
· Share with third parties on an anonymous or desensitized basis (i.e. no natural person can be identified by such information);
· Share information with other third parties whose intervention will promote, enhance, improve, or extend the services or products offered or sold to you or is necessary or related to or related to the performance of the contract entered into with you.
· If the business needs to provide your personal information, we will inform you of the purpose of providing personal information, the name or name of the data recipient, contact information, processing purposes, processing methods and types of personal information, and obtain your separate consent, involving sensitive personal information, in addition to the above.
2.3 transfer
We will not transfer your personal information to any company, organization or individual, except in the following circumstances:
· Transfer subject to express consent. After obtaining your express consent or authorization, we will transfer your personal information to other parties;
· Administrative and judicial requirements stipulated or mandatory by laws and regulations;
· When a merger, acquisition or bankruptcy liquidation is involved, such as the transfer of personal information, we will require the new company or organization that holds your personal information to continue to be bound by this privacy policy, otherwise we will require the company or organization to seek authorization from you again.
2.4 Public disclosure
If we need to publicly disclose your personal information, we will inform you and obtain your express consent, before public disclosure we will carry out a security impact assessment, and under the premise of taking effective protective measures, except in cases directly related to national security, national defense security, public safety, public health, major public interests or criminal investigation, prosecution, trial and execution of sentences. We will not publicly disclose your personal biometric information and other personal physiological information, and will not publicly disclose your race, ethnicity, political views, religious beliefs and other sensitive data analysis results.
3 Cookies and other recording tools
Cookies are text files placed by the web server on your visiting device, which will help you invoke information in subsequent visits and simplify the process of recording your personal information. Our website may use cookies and other recording tools. Using cookies on our website gives you benefits, such as allowing you to save your registered account when you visit. The use of cookies also allows us to detect the activity of the website in order to provide a better experience to our users. Cookies and other recording tools can be used to tell us the number and length of visits you have made, the pages you have visited, the websites you have visited before visiting our website, and the name of your Internet service provider.
You have the right to accept or reject cookies. If the browser automatically accepts cookies, you can modify the Settings of the browser to reject cookies according to your own needs. Please note that if you opt out of cookies, you may not be able to fully experience the services we offer.
4 How do we protect and store your personal information
4.1 Protection of personal information
Your personal privacy and information security are key considerations when we provide our products and services. We have taken specific steps to address privacy and security concerns as required by law. We recognize that it is important to protect our customers’ personal information from theft, improper use or improper dissemination. We will take all appropriate physical, electronic and administrative measures to protect your personal information in order to meet our commitment to information security.
When you provide us with sensitive personal information, we will take reasonable steps to protect your sensitive personal information, and we will also take reasonable security measures to protect the stored personal information. Our data security protection technology conforms to current industry standards. When you provide sensitive personal information through our website, this information is automatically encrypted for subsequent secure transmission. If our affiliates and partners obtain your personal information with your and our permission, they are required to strictly comply with the information confidentiality responsibilities of this policy and take appropriate security measures to protect your personal data.
You are as responsible as we are for the security of your information. You should keep your personal information safe and should not disclose it to or allow any other person to use it. If you believe that your personal information has been lost, stolen or used under a false name, and may affect your legal relationship with us, you are responsible for notifying us immediately so that appropriate measures can be taken to prevent further loss.
When leakage, damage, loss, or tampering of your personal information occurs or may occur, we will initiate emergency plans and response mechanisms, take immediate remedial measures, and inform you in time (including but not limited to through telephone, email, or website announcements, etc.), and report to the relevant competent authorities in accordance with laws, regulations, and regulatory provisions.
4.2 Storage of personal information and data exit
We will retain the information we collect from you in order to provide you with the services and products you have requested. We will keep your personal information for as long as it is reasonably necessary to provide you with our services and products. Once your contractual relationship with us is terminated, we will store and process your personal information in accordance with the relevant laws and regulations and compliance requirements, or the requirements of the corresponding credit policy and management system on the manner and period of retention of information, or as necessary for us to fulfill other relevant legal obligations (such as prosecution, enforcement or defense of legal claims).
In principle, the personal information we collect and generate in the People’s Republic of China will be stored in the People’s Republic of China. If the cross-border transmission of data has to occur according to your instructions or requirements, please comply with the requirements of relevant laws and regulations, and we can provide relevant assistance and assistance. As the client of personal information and data processing, you shall comply with all rules and requirements for cross-border provision of personal information and data in accordance with the Data Security Law of the People’s Republic of China, the Personal Information Protection Law of the People’s Republic of China and other provisions, including but not limited to obtaining the explicit authorization and consent of the personal information subject and meeting the necessary conditions for cross-border provision. You shall be liable for any damage or loss caused to the personal data subject or to us by your failure to perform your obligations and duties in accordance with the above provisions.
5 Your rights
In accordance with the relevant laws, regulations and standards of China, as well as the common practices of other countries and regions, we guarantee that you exercise the following rights to your personal information:
5.1 Access to your personal information
You have the right to access your personal information in accordance with the provisions of this policy, except for the exceptions provided by laws and regulations;
5.2 Correct your personal information
If you find that the personal information we process about you is incorrect or incomplete, you have the right to request that we make a correction through the contact details in this Policy. We will respond to your request for correction within a reasonable time.
5.3 Delete your personal information
In the following cases, you can make a request to us to delete personal information:
· If we process personal information in violation of laws and regulations;
· If we collect and use your personal information without your consent;
· If our processing of personal information violates our agreement with you.
If we decide to respond to your request for deletion, we may at the same time notify the entities that have obtained your personal information from us, asking them to delete it in a timely manner, unless otherwise required by law or regulation, or these entities have your independent authorization.
When you delete information from our services, we may not immediately delete the corresponding information from the backup system, but we will delete it when the backup is updated.
5.4 Withdraw your consent
For the collection and use of your personal information, you can request to give or withdraw your consent at any time through our contact information below. When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out on the basis of your authorization. You have the right to refuse to receive commercial advertisements based on your personal information, you can inform us through the contact information of this policy, we will not stop providing our core business and necessary personal information processing because of your refusal or withdrawal.
5.5 The personal data subject cancels the account
You can cancel your previously registered account at any time by contacting us in this policy. After the cancellation of the account, we will stop providing you with the corresponding products or services, if you also ask to delete your personal information, we will deal with your request to delete your personal information in accordance with the provisions of Item 3 above and Item 8 below.
5.6 The personal data subject obtains a copy of personal information
You have the right to request a copy of your basic personal information (such as your name and account name) through our contact information in this policy.
5.7 Constrained information system automatic decision
In some business functions, we may make decisions based on artificial automatic decision-making mechanisms, such as information systems, algorithms, etc., such as targeted push marketing information based on user purchasing habits (product type, price, etc.). If these decisions significantly affect your or your users’ legitimate rights and interests, you can let us know through the contact details in this policy, we support manual review of the results of automated decisions, and we will regularly communicate with you to improve the automated decision mechanism.
5.8 In response to your above request
For security purposes, you may be required to provide us with a written request through the contact details in this policy and to prove your identity. We may need to verify your identity before processing your request, which will be responded to within a reasonable period of time.
We may refuse requests that are unnecessarily repetitive, require too much technology, pose a risk to the legitimate interests of others, or are highly impractical.
In the following circumstances, according to the requirements of laws and regulations, we will not be able to respond to your request:
· Related to the performance by the personal information controller of the obligations stipulated by laws and regulations;
· Directly related to national security and national defense security;
· Directly related to public safety, public health or major public interests;
· Directly related to criminal investigation, prosecution, trial and execution of judgments;
· There is sufficient evidence that you have subjective malice or abuse of rights;
· Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations, or lead to the violation of other relevant laws and valid and lawful contract terms;
· Involving trade secrets.
However, please understand that due to the relevant laws and regulations, policies and compliance requirements updated from time to time, or the company’s corresponding credit and management system, the specific information you provide may not be corrected, deleted, revoked or cancelled, but we will inform you by reasonable means.
6 Third party service
To better serve you, you may receive content or web links from third parties from us and our partners. Please note that we have no control over such third parties. You can choose whether to access links, content, products and services provided by third parties.
You can choose whether to access links, content, products and services provided by third parties. We have no control over the personal information protection and privacy policies of third parties and such third parties are not subject to this policy. Before you submit personal information to a third party, please ensure that you read and agree with the privacy policy of the third party. If you agree that the aforesaid third-party service provider collects the aforesaid information and the information leaks, the relevant third-party service provider shall bear the corresponding legal responsibility.
7 Personal information of minors
Any child under the age of 14 May not register and use our Platform without the express consent of the guardian. We do not collect personal information from any minor unless we have the prior consent of the minor’s guardian. If we discover that we have collected personal information from a minor without the prior consent of a verifiable parent or other guardian, we will try to delete the data as soon as possible.
8 Dispute resolution
You and JINGdigital agree that any content of this privacy policy shall be governed by the laws of the People’s Republic of China. If any of the terms are in conflict with the law, these terms will be interpreted as close as possible to the literal meaning of the original terms, while other terms will remain legal effect and impact on you, due to the interpretation of this privacy Policy and your use of our Services, will agree to (and only) accept the jurisdiction of Shanghai Jing ‘an District People’s Court.
9 Disclaimer with updates to this policy
Although we are committed to continuously improving your use experience, we cannot guarantee that the network service will not be interrupted, or fully meet your requirements, JINGdigital is not responsible for the timeliness, correctness, effectiveness, stability, availability, integrity, authenticity and corresponding responsibilities and consequences of the network service of this website.
We are not responsible for network service interruption, personal information disclosure or other defects caused by force majeure or reasons beyond our control, but we will notify you in a timely manner in accordance with this policy and try our best to reduce the loss and impact caused to you.
According to changes in national laws and regulations and service operation needs, we may revise and update this policy from time to time. If such change or modification results in a material change in your rights under this Policy, we will provide you with prominent notice and obtain your consent. Any changes to the Privacy policy will be published and posted on our website. In order to better protect your personal information, we encourage you to visit our website frequently and recommend that you read the updated Privacy Policy in full.
10 Contact information
If you have any questions or intend to make suggestions about this privacy policy, or if you think that we have infringed your personal information rights and interests, you can contact us through the following ways:
Company name: Shanghai Jingdigital Network Technology Co., LTD
Contact us: +(86)400-104-0808
Contact email: info@jingdigital.com
Address: 18F, No. 888 Wanhangdu Road, Jing ‘an District, Shanghai, China
We will deal with it promptly and get back to you within a reasonable time.
This policy does not limit your rights as a personal data subject under the laws of the People’s Republic of China.
