In order to facilitate your logging in the website of ChangXin Memory Technologies, Inc. (as updated from time to time, the “Platform”) and use of relevant services thereon and provide you with more personalized user experience and services, we may collect and use your personal information when you use our services. Through this Policy, we hope to explain to you how we collect, use, store and disclose your personal information and how we allow you to access, update, control and protection of such information when logging in the Platform through the computer or mobile terminals. Please read this Policy carefully since it is related to the information you use on the Platform.
By using our services, you are deemed to have agreed to our collection, use, storage and disclosure of your personal information and the control and protection measures we take for the benefit of you in accordance with this Policy.
1. Scope of application
1.1 This Policy applies to all services on the Platform, including page browsing service, website login service and technical services provided to you through the Platform.
1.2 It should be noted that if you, as a user of the Platform, use the technical services on the Platform to provide services for your own users, you should separately agree with your users on a privacy policy since your business data belongs to you.
1.3 Any reference to “information” in this Policy shall mean the information collected under Article 2 hereof. This Policy does not apply to the data you store in the system of the Platform.
2. What kind of information will we collect
2.1 In order to complete account registration, management, real name authentication and other necessary activities on the Platform, you need to submit true, legal and effective information about you, including but not limited to your name, ID card number, contact number, facial biological information, bank account information, business registration information, etc.
2.2 When you use our service, we may collect the following information that we obtain from you with your authorization or that is filled in by yourself:
2.2.1 Location information, i.e., the information collected about your location when you enable the location function of the device and use our location-based services, including:
• Your geographic location information collected by GPS or WiFi when you use our services through mobile devices with location function.
• Real-time information containing your geographical location provided by you or other users, such as your area information contained in the account information provided by you, shared information showing your current or former geographical location uploaded by you, and the geographic tag information contained in the photos shared by you or others.
• You can stop our collection of your geographic location information by disabling the location function.
2.3 If you need to use some optional functions or services, such as sending resumes, making a consultation, etc., you need to provide the information necessary to use the functions or services, such as the contact person, contact number, ID card, a photo, etc.
2.4 If you need to apply online for offline delivery or product testing, you need to provide necessary information such as the contact person, contact number, address, etc.
3. How we will collect your information
3.1 We will collect your information from the data submitted by yourself and the records generated during your use of our services.
3.2 We may collect and use your information through cookies and other relevant technologies. We may use the cookies for the following purpose:
• To remember your identity. For example, cookies can help us identify you as our registered user.
• To analyze the situation of your use of our services in order to provide you with more thoughtful personalized services, including customized pages,
recommendations and other services.
3.4 The relevant information recorded through cookies on the Platform will be subject to this Policy.
4. How will we use your information
In order to provide you with high-quality, more convenient and safe services and subject to relevant laws and regulations, we may use the information we collect from you for the following purposes:
• To provide you with our services. Your real-name authentication information, your mobile phone number used to receive verification code, for example, is the premise of your continuing to obtain our services);
• To meet your personalized needs, personalized help services and instructions, or other responses to you and other users.
• For the purpose of service optimization and development. For example, we will optimize our services according to the information generated when the Platform system responds to your need.
5. How will we share, transfer and disclose your information
5.1 Share
We will not share your user information with other organizations and individuals, provided that,
5.1.1 We may share your user information with other parties after obtaining your explicit consent;
5.1.2 We may share your user information with outside parties in accordance with the laws and regulations, to meet the needs of litigation and arbitration, or as required by the administrative and judicial authorities;
5.1.3 In some cases, only by sharing your user information can we facilitate the handling of disputes between you and others.
5.1.4 We may entrust reliable partners to provide some services (such as face recognition services), so we may share some of your user information with such partners to enable them to provide better customer service and optimize user experience. We will only share your user information for legal, legitimate, necessary, specific and clear purpose, and only share the user information necessary to provide services. Our partners have no right to use your user information so shared for any other purpose. At present, our authorized partners include suppliers, service providers and other partners. We share your user information with suppliers, service providers and other partners that support our business, including providing basic technical services, consulting, analysis and other professional services. For companies, organizations and individuals with whom we share your user information, we will enter into confidentiality and non-disclosure agreements with them, requiring them to handle your user information in accordance with our instructions, this Policy and take any other relevant confidentiality and security measures.
5.2 Transfer
We will not transfer your user information to any company, organization or individual, provided that
5.2.1 We may transfer your user information to other parties after obtaining your explicit consent.
5.3 Disclosure
Without your prior consent, we will not share your information with any unrelated third party, provided that,
5.3.1 We may share your information with our affiliates, third-party service providers, contractors and agents solely for the following purpose:
• To provide the functions or services specified in “2. What kind of information will we collect” and to meet the purposes specified in “4. How will we use your information”.
• To fulfill our obligations and exercise our rights under the Personal Information Protection Policy or this Policy.
If we share your information with any third party mentioned above, we will strive to ensure that the third party complies with this Policy and takes other appropriate confidentiality and security measures we require when using your information.
5.3.2 With the continuous development of our business, we may conduct such transactions as merger,and your information may be transferred as part of such transactions.
However, we will, notify you prior to the transfer, ensure the confidentiality of the information during the transfer, and continue to perform the relevant responsibilities and obligations after the transfer.
5.3.3 We may also disclose your information for the following reasons:
• To comply with applicable laws and regulations.
• To comply with the court decisions, rulings or other legal proceedings.
• To comply with the requirements of relevant government authorities or other competent authorities.
• To disclose your information when we have reason to believe that we need to do so to comply with laws and regulations.
• To use your information reasonably necessary for the performance of relevant service agreements or this Policy, the safeguarding of social and public interests, the handling of complaints/disputes, and the protection of the personal and property safety or legitimate rights and interests of us, our customers or affiliates, other users or employees.
• If we disclose your information for the above reasons, we will inform you in a timely manner and obtain your legal authorization on the basis of complying with relevant laws and regulations and this Policy.
6. How will we store your information
6.1 The information about you collected by the Platform is stored on the server of the Platform located in Chinese Mainland.
6.2 Generally, we only retain your information during the service period for you, and the retention time will not exceed the time necessary to meet the relevant use purpose. However, under the following circumstances, and only for the purposes related to the following circumstances, we may need to retain your information or part of it for a long time:
• Comply with applicable laws and regulations.
• Comply with the requirements of court decisions, rulings or other legal proceedings.
• Comply with the requirements of relevant government authorities or other competent authorities.
• We have reason to believe that we need to comply with laws and regulations.
• Use reasonably necessary for the implementation of relevant service agreements or this Policy, the maintenance of social and public interests, the handling of complaints/disputes, and the protection of the personal and property safety or legitimate rights and interests of our customers, us or our affiliates, other users or employees.
7. How will we maintain the security of your information
7.1 If you have any other account registered on the Platform, for example, the account you registered on the Platform via WeChat payment, the personal information of your current account may be associated with the information of other account you have registered on this Platform under certain circumstances.
7.2 We strive to ensure information security to prevent any loss, improper use, unauthorized reading or disclosure of your user information.
• We use various security technologies to ensure the security of your user information. For example, we will prevent information disclosure, damage and loss through multiple server backups, password encryption and other security measures.
• We have rigorous management systems and process in place to ensure the security of your user information. For example, we only allow persons who need to access your user information to access it and conduct audits to require them to fulfil confidentiality obligations.
• We attach great importance to information security compliance, and have passed many international and domestic security certification, such as network security level protection certification, to fully guarantee your information security with industry-advanced solutions.
Nevertheless, please understand that even if we do our best to strengthen security measures, it is not always possible to ensure 100% security of your user information in the Internet environment due to technical limitations and possible malicious means, and that the system and communication network you use to access our services may have problems due to factors beyond our control.
In case of personal information disclosure or similar security event, we will activate the emergency plan to prevent the expansion of the security event, timely report it in accordance with the National Network Security Emergency Plan and other relevant provisions, and inform you of the relevant situation by the forms of email, notification, announcement, etc., and provide you with security suggestions.
7.3 In order to ensure your information security in a more effective manner, we also hope that you can strengthen your awareness of self-protection, and we will only assume direct economic loss resulting from the disclosure of your personal information directly caused by the Platform. Therefore, please keep your account and password information properly to avoid the disclosure of your personal information. Although the Platform account and WeChat account have security protection functions, you also need to properly protect your personal information, and shall not provide your account password and other personal information to any third party unless you think it is necessary.
8. How are you allowed to access and control your information
8.1 You can access, modify or delete your personal information in the process of using our services, and the way you access, modify and delete the information will depend on the specific service you use.
8.2 If you find that we have collected and used your information in violation of laws and regulations or the agreement of both parties, you may ask us to delete it, or, if you find that your information collected and stored by us is incorrect and cannot be corrected by yourself, you may ask us to correct it.
8.3 When accessing, modifying or deleting relevant information, we may require you to perform authentication to ensure your account security. Please understand that some of your requests may not be responded to due to technical limitations or legal and regulatory requirements.
8.4 Some of your information may not be accessible, modified or deleted for legitimate reasons such as legal and regulatory requirements and information security.
8.5 You may choose to withdraw your consent to the processing of your personal information by some non-basic functions or services, and cancel the account you registered on the Platform by contacting customer service;
8.6 You may contact us according to the contact information specified in “10. Contact us” if you have any question about the realization of the above rights.
9. Update of this Policy
We may amend the terms of this Policy , and such amendment shall form a part of this Policy. If such amendment substantially impairs your rights hereunder or expands the scope of collection and use of your personal information, or results in the change of any other important rules, we will notify you by noticing on the home page of the Platform or sending you an email or other means before the amendment takes effect.In such case, by continuously using our service, you will be deemed to have agreed to be bound by the amended Policy.
10. Contact us
If you have any questions about this Policy or other relevant matters, you may fill in the feedback according to our guidance. We will review the questions as soon as possible and reply after verifying your user identity.
