Online Service Platform Privacy Agreement
Dear users of the Online Service Platform (hereinafter referred to as “you”), in order to facilitate your use of the Online Service Platform (hereinafter referred to as “the Platform”), the Platform will collect, use, store, and disclose your user information in accordance with the Online Service Platform User Privacy Policy (hereinafter referred to as “this Policy”). This Policy applies to all access to and use of the Platform by you through any means.
When you use the Platform’s services, the Platform must collect, store, use, and share your information, in accordance with the requirements of the Civil Code of the People’s Republic of China, the Cybersecurity Law of the People’s Republic of China, and other applicable national laws and regulations. The purpose is to provide services to you, improve service quality, and explain clearly: what data the Platform collects when you use its services, why such data is collected, how it is used, and how it is protected. This Policy is closely related to the services you use and is crucial for exercising your user rights and protecting your information. Please read and fully understand this Policy before using the Platform’s services.
Before clicking to confirm this Policy, please carefully read it and ensure that you understand the rules governing how the Platform handles your information. If you click “Agree” and confirm submission, or if you use the Platform (whichever occurs first), you will be deemed to have agreed to the content of this Policy (including updated versions) and consent to the Platform’s collection, use, storage, and disclosure of your information in accordance with this Policy.
Please make sure you carefully read and fully understand each clause, especially those marked in bold and underlined, which involve limitation of liability, applicable law, and dispute resolution. Please note that the personal information highlighted in bold and underlined is considered sensitive information, and the system permissions marked likewise are sensitive permissions. You should carefully consider before providing such information or granting such permissions.
I.Collection and Use of Your Information
A.Statement of Responsibility
The Platform is responsible for collecting, managing, and maintaining users’ authentic information as well as behavioral data generated by the Platform. Mandatory business-related information will be collected in accordance with operational requirements. Where necessary, third-party service systems may share your user information or conduct secondary authentication. The Platform will, based on the current state of technology, implement appropriate security measures to prevent the loss, leakage, misuse, or alteration of information. If user information or business information is disclosed due to circumstances beyond the Platform’s control, the Platform shall bear no liability.
B.Collection of Information
To ensure the security of your use of the Platform and to improve your overall experience, the Platform may collect, use, and retain the following personal information related to you:
1.When using the Platform’s “Register” function, you are required to provide your Name, Email Address, Job Title, and Company/Organization, and you agree that the Platform may verify the accuracy and validity of the information provided.
2.If the Platform intends to use your information for purposes beyond those explicitly stated at the time of collection, or beyond a scope that is directly or reasonably related thereto, the Platform shall notify you in advance and obtain your explicit consent before such use.
C.Use of Information
1.Subject to applicable laws and regulations, the Platform may use the collected information for the following purposes:
i.Provision of Services – To deliver the services offered by the Platform to you.
ii.Optimization and Development of Services – For example, the Platform may analyze information generated while responding to your requests to improve its services. Such information shall not include personally identifiable data.
iii.Protection of Personal and Public Safety – To protect your personal and property security, as well as that of other users and the public, and to prevent phishing websites, fraud, security vulnerabilities, computer viruses, cyberattacks, and intrusions. To more accurately identify violations of laws, regulations, or Platform-related agreements and rules, the Platform may use your account information, integrate device data and network logs, and rely on information shared by governmental authorities or partners to assess account risks, verify identities, detect and prevent security incidents, and lawfully implement measures such as record-keeping, auditing, analysis, and incident handling. For example, your information may be used for identity verification, security protection, complaint handling, dispute resolution, and fraud monitoring.
2.Other Purposes – Any other purposes explicitly authorized by you or as required under applicable laws and regulations.
II.Use of Cookies and Similar Technologies
The Platform may utilize Cookies (data stored locally on a user’s device) and other related technologies to collect and process your information. The specific purposes of using Cookies include:
1.Service Analysis and Personalization – To analyze how you use the Platform’s services, to provide you with more comprehensive and personalized services, such as customized pages, recommendations, and related features.
2.User Control – You may refuse or manage Cookies through browser settings or other tools. However, please be advised that disabling Cookies may prevent you from enjoying the optimal service experience, and certain functionalities of the Platform may become unavailable or impaired.
III.Sharing, Transfer, and Public Disclosure of Your Information
A.Sharing
The Platform will not share your information with companies, organizations, or individuals outside of the Platform, except where many services are provided by third-party systems and information sharing is required for business processing. In such cases, the following principles will be observed:
1.Sharing with Explicit Consent – With your explicit consent, the Platform may share your information with third parties.
2.Sharing Under Legal Circumstances – The Platform may share your information externally as required under applicable laws and regulations, for dispute resolution, or pursuant to requests made by administrative or judicial authorities in accordance with the law.
3.Sharing for Service Provision or Dispute Resolution – In certain cases, sharing your information is necessary to facilitate service provision or to assist in resolving disputes between you and others.
4.Sharing with Authorized Third-Party Service Providers – To better provide services, the Platform may engage authorized third-party service providers to deliver specific services or perform functions on its behalf. The Platform will only share your information for lawful, legitimate, necessary, specific, and explicit purposes as stated in this Policy. Such third parties may only access the information necessary to fulfill their duties and may not use it for any other purpose. The Platform may share your Name, Email Address, and other information necessary for the use of third-party products or services. If the Platform intends to share information beyond the necessary details, or if the third-party service provider changes the purposes or manner of processing user information, the Platform will again seek your explicit consent.
B.Transfer
The Platform will not transfer your user information to any company, organization, or individual, except in the following circumstances:
1.Where your prior consent has been obtained.
2.Where the transfer is required under applicable laws, legal procedures, or mandatory administrative or judicial requests.
C.Public Disclosure
The Platform will only publicly disclose your information under the following circumstances:
1.With your explicit consent or based on your voluntary choice, the Platform may publicly disclose your information.
2.If the Platform determines that you have violated applicable laws, regulations, or materially breached Platform agreements or rules, or where necessary to protect the personal and property safety of the Platform or the public, the Platform may, in compliance with laws, court orders, legal proceedings, or requests of competent government authorities, disclose your information, including the nature of the violation and any measures taken against you.
3.Pursuant to national policy arrangements or legal requirements, if the Platform or relevant government agencies undergo organizational restructuring, asset transfer, or similar transactions, your information may be transferred as part of such transactions. The Platform will comply with applicable laws and regulations, notify you prior to transfer, ensure confidentiality of information during the process, and continue to fulfill corresponding responsibilities and obligations after the transfer.
D.Exceptions to Prior Consent for Sharing, Transfer, or Disclosure
In the following circumstances, the Platform may share, transfer, or publicly disclose your information without first obtaining your authorization or consent:
1.Where it is related to national security or defense.
2.Where it is related to public safety, public health, or significant public interest.
3.Where it is related to criminal investigation, prosecution, trial, or enforcement of judgments.
4.Where it is necessary to protect your or another individual’s life, property, or other major lawful rights and interests, and obtaining consent is difficult.
5.Where you have voluntarily made the information available to the public.
6.Where the information is collected from legally and publicly disclosed sources, such as lawful news reports or government information disclosure.
7.Where it is necessary for the Platform to comply with laws, regulations, or the requirements of industry regulators.
8.Other circumstances as permitted under applicable national requirements.
IV.Retention of Your Information
The user information collected and generated within the territory of the People’s Republic of China will be stored domestically within the People’s Republic of China. The Platform will retain your information only for the period necessary to fulfill the purposes set out in this Policy and within the time limits prescribed by applicable laws and regulations. Upon the expiration of such retention periods, the Platform will anonymize the collected information.
During the period in which you use the Platform’s services, the Platform will continue to retain your information. Once you submit a request for the deletion of your personal information, the Platform will retain such information only for the time limits prescribed by applicable laws and regulations, and for the period necessary to achieve the purposes set forth in this Policy. After the expiration of the retention period, the Platform will delete or anonymize your personal information.
In the following circumstances, and solely for the purposes related thereto, the Platform may need to retain your information, or part thereof, for an extended period:
1.To comply with applicable laws and regulations.
2.To comply with court judgments, rulings, or other legal proceedings.
3.To comply with requests of relevant government authorities or other competent bodies.
4.Where the Platform has reasonable grounds to believe it is necessary to comply with applicable laws and regulations.
5.To perform service agreements or this Privacy Policy, safeguard public interests, resolve complaints or disputes, or protect the personal safety, property, or other lawful rights and interests of the public.
V.How You May Manage Your Information
A.Deletion of Your Information
You may request the deletion of your information from the Platform under the following circumstances:
1.Where the Platform’s handling of your information violates applicable laws or regulations.
2.Where the Platform collects or uses your information without obtaining your consent.
3.Where the Platform’s handling of your information breaches the terms agreed upon with you.
4.Where you no longer use the Platform’s services.
5.Where the Platform ceases to provide services to you.
6.Other circumstances as provided for by laws and administrative regulations.
When you delete information from the Platform’s services, the Platform may not immediately remove the corresponding data from its backup systems; however, such data will be deleted or anonymized upon the next scheduled update of the backup.
B.Response to Your Requests
For security purposes, you may be required to submit a written request or otherwise provide proof of your identity. The Platform may ask you to verify your identity before processing your request. Please understand that the Platform may decline requests that are manifestly unfounded, involve excessive technical efforts, pose risks to the legitimate rights and interests of others, or are otherwise impractical.
Notwithstanding the foregoing, in accordance with applicable laws and regulations, the Platform may be unable to accommodate your request in the following situations:
1.Where it relates to national security or defense.
2.Where it relates to public security, public health, or significant public interests.
3.Where it relates to criminal investigation, prosecution, trial, or enforcement of judgments.
4.Where there is sufficient evidence of your subjective malice or abuse of rights.
5.Where responding to your request would cause serious harm to the lawful rights and interests of you, other individuals, or organizations.
6.Where the request involves trade secrets.
7.Where it is necessary to comply with anti-money laundering or sanctions obligations.
VI.Exceptions to Obtaining Consent
In accordance with applicable laws and regulations, the Platform may collect and use your information without obtaining your separate authorization or consent under the following circumstances:
1.Where it is directly related to national security or national defense.
2.Where it is directly related to public security, public health, or significant public interests.
3.Where it is directly related to criminal investigation, prosecution, trial, or enforcement of judgments.
4.Where it is necessary to protect your life, property, or other significant lawful rights and interests, or those of another individual, but it is difficult to obtain your consent in a timely manner.
5.Where the information is disclosed by you voluntarily to the public.
6.Where the information is collected from legally and publicly disclosed sources, such as lawful news reports or government information disclosure.
7.Where it is necessary for the conclusion or performance of a contract at your request.
8.Where it is necessary to maintain the safe and stable operation of the services provided by the Platform, such as identifying and addressing service failures, fraud, or misuse.
9.Where it is necessary to fulfill statutory obligations under applicable laws, regulations, or the requirements of competent industry authorities.
10.Where the Platform or third-party services integrated with the Platform are government agencies or entities vested with administrative authority by law, and the collection or use of user data is necessary for the performance of public duties.
VII.How the Platform Protects Your Information
The Platform is committed to safeguarding the security of user information to prevent loss, misuse, unauthorized access, or public disclosure.
A.Security Measures
To protect your information, the Platform will adopt security measures consistent with industry standards, considering applicable legal and regulatory requirements and the current level of technological development. The Platform will employ physical, technical, and administrative safeguards to mitigate the risks of loss, misuse, unauthorized access, disclosure, or alteration, and will make every effort to prevent data from being improperly accessed, disclosed, used, modified, damaged, or lost.
B.Internal Management
The Platform has established dedicated management systems, processes, and organizational structures to ensure the security of information. Access to information is strictly limited to authorized personnel only, who are bound by confidentiality obligations and subject to audit.
C.Service Suspension or Interruption
If the Platform discontinues part or all the governmental or convenience services it provides, it will notify you through messages, pop-up prompts, or other means, and will cease collecting your information related to those services to protect its security. If services become unavailable due to technical failures, cyberattacks, natural disasters, accidents, or human factors, the Platform will implement emergency response and recovery measures to address the incident and restore services as soon as possible.
D.Incident Response
Given that the internet environment cannot be guaranteed to be 100% secure, the Platform will make best efforts to ensure the safety of your information. If physical, technical, or administrative protection measures are compromised, resulting in unauthorized access, public disclosure, alteration, destruction, or other personal information security incidents, the Platform will immediately activate its emergency response plan to contain the incident, and will notify you of the situation through messages or other means. At the same time, the Platform will report the handling of such personal information security incidents in accordance with applicable requirements.
E.Data Minimization
The Platform will take all reasonable and practical measures to ensure that no personal information unrelated to the services you use is collected.
VIII.Protection of Minors’ Information
1.The Platform expects parents or legal guardians to supervise minors in their use of the Platform’s services. The Platform will protect the confidentiality and security of minors’ information in accordance with applicable national laws and regulations.
2.If you are a minor, your parents or legal guardians should carefully read this Policy, and you may only use the Platform’s services or provide information to the Platform with their consent. If your parents or legal guardians do not agree to your use of the Platform’s services or the provision of your information in accordance with this Policy, you should immediately cease using the Platform’s services and promptly notify the Platform so that appropriate measures may be taken.
3.In cases where information of minors is collected with the consent of their parents or legal guardians, the Platform will use or disclose such information only as permitted by law, with the explicit consent of the parents or guardians, or where it is necessary to protect the minor. If parents or guardians discover that the Platform has collected information of a minor without their consent, they should promptly notify the Platform, and the Platform will endeavor to delete the relevant data as quickly as possible.
IX.Storage and Transfer of Your Information
User information collected within the territory of the People’s Republic of China will be stored domestically within the People’s Republic of China. The Platform will retain your information only for the period necessary to fulfill the purposes set forth in this Policy and within the retention periods required under applicable laws and regulations.
If it becomes necessary to transfer your information outside of China, the Platform will:
1.Obtain your separate authorization and consent, and complete the required statutory procedures, ensuring that your information is afforded adequate protection in accordance with the applicable laws in effect at the time of transfer; and
2.Ensure that such transfer is conducted in compliance with applicable legal requirements. Even if your authorization has been obtained, the Platform will not proceed with the transfer if the method or purpose of transfer is inconsistent with relevant laws and regulations.
X.Updates to This Policy
In the event of changes in applicable laws or regulations, or where necessary due to adjustments in the services provided by the Platform, this Policy will be amended accordingly and shall replace any prior versions. If you do not agree with the revised content, you should promptly contact the Platform or immediately cease using the services governed by this Policy. If you choose to agree to or continue using the relevant services, you shall be deemed to have fully accepted and consented to the updated content. If, due to objective circumstances or business adjustments, the Platform needs to suspend or discontinue the relevant services, the Platform will provide timely notice. You are expected to acknowledge and understand such changes.
XI.Miscellaneous
A.The establishment, validity, performance, interpretation, and dispute resolution of this Policy shall be governed by the laws of mainland China. Where the law is silent, generally accepted domestic practices may apply.
B.If any provision of this Policy is held to be invalid or unenforceable for any reason, the validity and enforceability of the remaining provisions shall not be affected.
C.Matters not expressly covered in this Policy shall be handled in accordance with applicable laws and regulations, relevant business rules of the Platform, and generally accepted domestic practices.
D.Any disputes arising from the content or performance of this Policy shall be resolved through amicable negotiation between the parties. If no agreement can be reached, such disputes shall be submitted to the People’s Court with jurisdiction at the location of the Platform’s operator.
E.This Policy is written in Chinese and may be translated into other languages. In the event of any inconsistency between the Chinese version and a translated version, the Chinese version shall prevail.