.
(7) In order to ensure the security of your account, after obtaining your consent, we will collect device information (unique device identifiers IMEI, IMSI) by reading the user's phone status.
2. The above additional functions may require you to enable us to access your geographic location (location information), camera (camera), photo album (picture library), third-party service platform (Weibo, WeChat, etc.) in your device , to enable the collection and use of information involved in these functions. You can also decide to turn these permissions on or off at any time. Please note that when you enable these permissions, you authorize us to collect and use this personal information and other information to achieve the above functions. If you close the permissions, you cancel these authorizations, and we will no longer continue to collect and use you. This personal information and other information cannot provide you with the above-mentioned functions corresponding to these authorizations. Your decision to close the permission will not affect the previous processing of personal information and other information based on your authorization.
(3) You are fully aware that in the following situations, we do not need your authorization and consent to collect and use personal information and other information:
1. Related to our performance of obligations stipulated by laws and regulations;
2. Those directly related to national security and national defense security;
3. Those directly related to public safety, public health, and major public interests;
4. Those directly related to criminal investigation, prosecution, trial and execution of judgments;
5. In order to protect your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain my consent;
6. The personal information and other information involved are disclosed to the public by you;
7. Necessary to sign a contract according to your request;
8. Your personal information and other information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
9. Necessary for maintaining the safe and stable operation of the products and/or services provided, such as finding and disposing of failures of the products and/or services;
10. Other circumstances stipulated by laws and regulations.
(4) Circumstances where we obtain your personal information and other information from third parties
[Third-party information] In order to jointly provide you with products/services or improve the quality and degree of personalization of products and services, or for reasonable needs such as considering the security of products and/or services, we follow laws and regulations or based on your Authorize to receive your personal information and other information from affiliates, alliance members, partners and other trusted third-party suppliers, service providers and agents. We will confirm the legitimacy of the source of third-party personal information, and use your personal information within the scope of your authorization and consent to the third party. If the products and/or functions we provide exceed your authorized scope of use, we or we will require the above-mentioned third parties to obtain your consent again. You understand and agree that we are not legally responsible for the collection and provision of such third parties.
(5) Rules for the use of your personal information and other information
1. We will legally use the collected personal information and other information in accordance with legal regulations and the stipulations of this Privacy Policy and in order to realize the functions of our products and/or services.
2. After collecting your personal information and other information, we may de-identify or anonymize such information through technical means in accordance with the law as the case may be. The de-identified information will not be able to identify the user subject, but It may be combined with other information to identify the user subject; the anonymized information will not be able to identify the user subject, and the processed information cannot be recovered.
3. [Usage Authorization] Please note that all personal information and other information you provide when using our products and/or services, unless you delete or refuse our collection through system settings, will be used when you use our products. and/or continue to authorize our use during the service.
4. We will make statistics on the use of our products and/or services, and may communicate with the public or third parties (including but not limited to communication service providers that send emails or push notifications on our behalf, and those who provide us with location data). map service providers, and financial service providers, etc.) share these statistical information to show the overall usage trends of our products and/or services, or to maintain and improve our services, but these statistical information does not contain any of your identity identifying information.
5. We will only share your personal information and other information based on legitimate purposes. At the same time, we will desensitize your information by means of content replacement and anonymization to protect the security of your personal information and other information.
2. how we use
Cookies and Similar Technologies
(1) Use of Cookies
1. In order to realize the personalized needs of your online experience, so that you can get an easier access experience. We send one or more small data files called cookies on your computer or mobile device, the cookies assigned to you
is unique, it can only be read by web servers in the domain that issued the cookies to you. We send you cookies to simplify your repeated login steps, store data such as your shopping preferences or the items in your shopping cart, and then provide you with shopping preferences, help you optimize your choice and interaction with advertisements, and help you judge you login status and account or data security.
2. We will not use cookies for any purpose other than those described in this Privacy Policy. You can manage or delete cookies according to your preferences. You can clear all saved on the relevant terminal
Cookies, most web browsers will automatically accept cookies, but you can usually modify the settings of your browser to reject cookies according to your needs; in addition, you can also clear all cookies saved in the software. However, if you do this, you may need to personally change the user settings every time you visit our website, and the corresponding information you have previously recorded will be deleted, which may have some impact on the security of the service you use.
(2) The use of network Beacon and similar technologies
In addition to cookies, we also use other similar technologies such as web beacons on our website. Our web pages often contain electronic images (called "single pixel"
GIF file or "web beacon"). We use network beacons in the following ways:
1. By using web beacon on our website, calculate the number of user visits, and identify registered Shufei users by accessing cookies.
2. Provide you with personalized services through the obtained cookies information.
3. Circumstances of sharing, transferring and publicly disclosing your personal information
(1) Sharing
1. We will not share your personal information with any company, organization or individual other than Shufei and its affiliates, except in the following cases:
(1) Obtain your explicit consent or authorization in advance through this Privacy Policy or other reasonable means, such as emails, phone calls, pop-up notifications, etc., and only for legal, legitimate, necessary, specific and explicit purposes;
(2) Provided in accordance with applicable laws and regulations, the requirements of legal procedures, and the requirements of administrative or judicial authorities. 2. You understand and agree that we may share your personal information with our affiliates for the purposes of improving user experience, optimizing products, providing you with better services based on linked accounts, providing personalized services, and identifying abnormalities in linked accounts. shared. We will only share necessary personal information and subject to the purposes stated in this Privacy Policy. If we share your personal sensitive information or our affiliates change the purpose of processing personal information, we will seek your authorization again.
3. You understand and agree that we may share with our advertisements, licensors, suppliers and other partners to provide better customer service and user experience, including but not limited to sharing with advertising or information service providers, to Help them improve the effective reach rate of push content and analyze the usage of our products and services without identifying you personally. We will only share necessary personal information and subject to the purposes stated in this Privacy Policy. If our partners want to change the purpose of processing personal information, they will seek your authorization again.
4. In order to better handle your complaints and improve the consumer protection mechanism, or when we plan to merge with other companies, be acquired by other companies or conduct other capital market activities (including but not limited to IPO, bond issuance, etc.) and therefore need When accepting due diligence from other entities, we may hire external professional intermediaries (such as law firms, accounting firms) to provide personally identifiable information, account information, and transaction information related to your complaint and prosecution to such institutions , but we will require them to take reasonable and necessary confidentiality measures for your personal information by signing confidentiality agreements with these subjects, and require them to delete your information within a reasonable period of time after completing the necessary work.
5. You understand and agree that our products and/or services may include third-party software tool development kits (SDKs) to collect and use your personal information in the form of embedded codes, plug-ins, etc. In order to implement related functions, third-party SDK service providers may collect your related personal information.
Please rest assured that we will require the software tool development kit (SDK) for third-party software to obtain relevant information to process personal information in accordance with the service purpose, service description, privacy policy and any other relevant confidentiality and security measures. In order to protect your legitimate rights and interests, if you find that such SDK or other similar applications are at risk, please immediately terminate the relevant operations and contact us in time.
6. In order to ensure the realization of program-related functions and the safe and stable operation of the application, the list of third-party SDK plug-ins we connect to is as follows
com.umeng (Youmeng)
Purpose of use: to help APP better understand user behavior, so as to provide better personalized services
Type of Data Collected: Device Identification Information
Official website link: https://www.umeng.com/
com.bytedance(Byte;ByteDance;Douyin;Volcano Video;Byte Video Player) and
com.bytedance.sdk.openadsdk
Purpose of use: help APP to better obtain commercial income to support better service users
Type of Data Collected: Device Identification Information
Official website link: https://www.pangle.cn/
com.qq.e.ads (Guangdiantong; Tencent Social) and
com.qq.e.comm (Guangdiantong; Tencent Social)
Purpose of use: help APP to better obtain commercial income to support better service users
Official website link: https://sso.e.qq.com/
Kuaishou Alliance SDK
Purpose of use: help APP to better obtain commercial income to support better service users
Type of Data Collected: Device Identification Information
Official website link: https://u.kuaishou.com/#/
Baidu Alliance SDK
Type of Data Collected: Device Identification Information
Purpose of use: help APP to better obtain commercial income to support better service users
Official website link: https://union.baidu.com/bqt/
com.huawei.hms (Huawei; Huawei Push)
Type of Data Collected: Device Identification Information
Purpose of use: to help better adapt to Huawei services
Official website link: https://developer.huawei.com/consumer/cn/
com.tencent.bugly(Bugly; Tencent Bugly)
Type of Data Collected: Device Identification Information
Purpose of use: to help better locate problems related to the product use process
Official website link: https://bugly.qq.com/v2/
com.taobao (Taobao; Mtop; Ali)
Type of Data Collected: Device Identification Information
Purpose of use: Help improve user experience, facilitate and better improve product stability
Official website link: https://www.taobao.com
Freso Platform SDK (com.facebook.fesco)
Type of Data Collected: Device Identification Information
Purpose of use: Improve user page loading speed
Official website link: https://www.fresco-cn.org/
com.netease (NetEase; NetEase IM; NetEase Yunxin)
Type of Data Collected: Device Identification Information
Purpose of use: to facilitate better understanding of user behavior to improve user experience
Official website link: https://www.163yun.com/
com.alipay (Alipay; Ali Ride Code; Ali Sesame Credit Real-Name Authentication; Sesame Authentication)
Type of Data Collected: Device Identification Information
Purpose of use: to provide payment-related services
Official website link: https://open.alipay.com/platform/home.htm
WeChat payment platform SDK (com.tencent)
Type of Data Collected: Device Identification Information
Purpose of use: to provide payment-related services
Official website link: https://pay.weixin.qq.com
com.tencent.smtt (TBS Tencent Browsing Service; Tencent Browsing Service; Tencent X5 Browser)
Type of Data Collected: Device Identification Information
Purpose of use: to facilitate better understanding of user behavior to improve user experience
Official website link: https://tencent.com
com.cmic.sso (Mobile; China Mobile)
Type of data collected: mobile phone number
Purpose of use: convenient for users to log in quickly
Official website link: https://cmic.com
com.tencent (QQ; King Card; Tencent; Tencent Guangdiantong; WeChat)
Type of data collected: User device information
Purpose of use: quick login for users
Official website link: https://tencent.com
(2) Transfer
We will not transfer your personal information to any companies, organizations and individuals, except in the following cases:
1. Obtain your prior consent or authorization; 2. Provide it in accordance with applicable laws and regulations, the requirements of legal procedures, and mandatory administrative or judicial requirements; 3. Comply with the relevant agreements signed with you (including online signing electronic agreement and the corresponding platform rules)or other legal documents agreed to provide;
4. When it comes to mergers, acquisitions, asset transfers or similar transactions, if it involves the transfer of personal information, we will require new companies and organizations that hold your personal information to continue to be bound by this Privacy Policy, otherwise, we will require The company or organization seeks your authorization and consent again.
(3) Public disclosure We will only publicly disclose your personal information under the following circumstances and on the premise of taking industry-standard security protection measures:
1. According to your needs, disclose the personal information you designate under the disclosure method that you expressly consent to; 2. In the case of providing your personal information according to the requirements of laws, regulations, mandatory administrative law enforcement or judicial requirements, We may publicly disclose your personal information depending on the type and disclosure of personal information requested. Under the premise of compliance with laws and regulations, when we receive the above-mentioned request for information disclosure, we will require the issuance of corresponding legal documents, such as subpoenas or investigation letters. We strongly believe in being as transparent as possible about the information we are asked to provide, to the extent permitted by law. All requests are carefully reviewed to ensure they have a legitimate basis and are limited to data law enforcement has a legitimate right to obtain for specific investigative purposes. Under the premise of laws and regulations, the files we disclose are under the protection of encryption keys.
4. How do we safely protect and save your personal information (1) Storage of information 1. Storage location
Personal information we collect and generate within the territory of the People's Republic of China is stored within the territory of the People's Republic of China. Shufei will not provide or store personal information outside the People's Republic of China.
2. Storage period We only retain your personal information for the time necessary to achieve the purpose of the service, unless otherwise stipulated by laws and regulations, we will store your information for the following periods:
(1) We will collect your personal information to meet our legitimate business needs, such as providing services to you or to meet corresponding legal, tax and financial requirements. (2) When we have no legitimate business needs to use your personal information, at your request, we will delete your personal data or anonymize it, or if anonymization or deletion is impossible Implemented (for example, your personal information has been stored in a backup), we will store your personal information securely and separate it from other data processing.
4. How we securely protect and store the information you provide
Our technologies and measures to protect your personal information
We take personal information security very seriously and take all reasonably practicable measures to protect your personal information:
(1) Data security technical measures
We promise that we will maintain information security to a reasonable level of security. In order to protect your information security, we are committed to using various security technologies and supporting management systems to prevent your information from being leaked, damaged or lost, including establishing reasonable system specifications and security technologies to prevent your personal information from being unauthorized. Authorized access to use, modify, and avoid damage or loss of data.
Shufei's network services adopt encryption technologies such as transport layer security protocols, and provide security services through https and other methods to ensure the security of data during transmission.
Shufei adopts a variety of encryption technologies to encrypt and store users' personal information, and conduct security domain isolation for storage media or information systems containing users' personal information through logical or physical isolation.
When using personal information, such as personal information display and personal information association calculation, we will use a variety of data desensitization technologies to desensitize sensitive fields to enhance the security of personal information in use.
(2) Other security measures taken by Shufei to protect personal information
Shufei regulates the security behavior of personal information in internal storage, use, sharing and other aspects by establishing an information classification and grading system, a user information security management system, and a security development specification.
Shufei conducts comprehensive security control of data through confidentiality agreements, monitoring and auditing mechanisms for information contacts.
Shufei monitors the behavior of the staff in handling your information, and continuously promotes relevant laws and regulations, privacy and security guidelines and security awareness for staff training. It also organizes all staff to take security exams and holds security and privacy protection training courses. , to enhance employees' awareness of the importance of protecting personal information.
(3) Information notification
Due to technical level limitations and various malicious means that may exist, problems may arise due to factors beyond our control. In the event of an unfortunate personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and the measures you can take to prevent and reduce risks on your own. Recommendations, remedies for you, etc. We will promptly notify you of the relevant information of the event by email, letter, telephone or push notification. When it is difficult to inform the subject of personal information one by one, we will publish an announcement in a reasonable and effective way. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.
If we stop operating, we will promptly stop the collection of your personal information, notify you of the cessation of operation by one-by-one delivery or announcement, and destroy or anonymize the personal information we hold.
5. How you access and control the personal information you provide
(1) The rights you can exercise over your personal information:
access your personal information
(1) You can log in to your account through Shufei, and check all your personal information, or make relevant privacy and security settings by means of online feedback.
(2) You can also request us to access personal information through customer service or the contact information shown in the "How to Contact Us" section.
Correct your personal information
(1) You can modify your nickname, avatar, gender and other information through settings.
(2) When you find that the personal information we process about you is wrong, you have the right to ask us to make corrections. You can apply for correction through the methods listed in "(1) Access to your personal information".
delete your personal information
In the following cases, you can request us to delete personal information by "(1) visiting our customer service
(1) If you find that our collection and use of your personal information violates the provisions of laws, administrative regulations, or violates the agreement with you or does not obtain your consent;
(2) If you no longer use our products and/or services, or you cancel your account;
(3) If we no longer provide you with products and/or services.
Please note: When you delete information from our services, we may not delete the corresponding information from the backup system immediately, but will delete the information when the backup is updated (but the hotspot owner cancels the hotspot sharing, it will be cancelled in time ).
Cancel your account
You have the right to cancel your registered account, and you can cancel your account by applying. After your account is cancelled, we will stop providing you with products and/or services, and promptly delete or de-identify your personal information in accordance with laws and regulations. We will solve it for you within [15 working days].
Change the scope of your authorization and consent
Each business function requires some basic personal information to be completed (see "1. How we collect and use your personal information and other information" in this Privacy Policy). For the collection and use of additionally collected personal information, you may give or withdraw your consent at any time. You can do it yourself by:
You can find Shufei products in the system settings - application management of your device and manage, modify or delete related permissions. 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 previous processing of personal information based on your authorization.
The personal information subject obtains a copy of the personal information
You have the right to obtain a copy of your personal information, you can ask us to obtain a copy of your personal information through customer service or the contact information shown in the "How to Contact Us" section, and we will provide it to you after verifying your identity.
Under the premise of technical feasibility, if the data interface has been matched, we can also directly transmit a copy of your personal information to a third party designated by you according to your request.
6. Notices and Amendments
1. In order to provide you with better services and with the development of Shufei's business, this privacy policy will also be updated from time to time. However, we will not reduce your rights under this Privacy Policy without your express consent. We will issue an updated version on the mobile terminal of Shufei products and remind you of the update of the relevant content through website announcements or other appropriate means before it takes effect. Please also visit Shufei to keep abreast of the latest privacy policy.
2. In case of major changes, we will inform you in a more prompt manner, including but not limited to sending emails, letters, telephone calls, push notifications, etc. Material changes referred to in this Privacy Policy include, but are not limited to:
(1) Significant changes in our service model, such as the purpose of processing personal information, the type of personal information processed, the way personal information is used, etc.;
(2) Significant changes have taken place in our ownership structure and organizational structure. Such as changes in owners caused by business adjustments, bankruptcy mergers and acquisitions, etc.;
(3) The main objects of personal information sharing, transfer or public disclosure have changed;
(4) Significant changes in your rights to participate in the processing of personal information and the manner in which it is exercised;
(5) When there are changes to the responsible department, contact information and complaint channels that we are responsible for handling personal information security;
(6) When the personal information security impact assessment report indicates that there is a high risk. We will also archive older versions of this policy for your review.
3. [Revision of Privacy Policy] The revisions we may make to this Privacy Policy constitute part of this Privacy Policy. By continuing to use our products and/or services, you agree to be bound by this revised Privacy Policy.
7. Applicable Law and Dispute Resolution 1. [Applicable Law] The implementation, interpretation and dispute resolution of this Privacy Policy shall be governed by the laws of the People's Republic of China, without regard to any conflict of laws.
2. [Dispute Resolution] If you and Shufei have any dispute over the content of this Privacy Policy or its implementation, the two parties shall resolve it through friendly negotiation. If the two parties cannot resolve the dispute through negotiation, both parties agree that the dispute should be submitted to the court with jurisdiction where the company is located for settlement.
7. Applicable Law and Dispute Resolution
1. If you find that your personal information is leaked, especially if your account is leaked, please contact us immediately through the contact information specified in [How to Contact Us] at the bottom of this policy, so that we can take corresponding measures.
2. Before responding to some of your requests under paragraph 1 above, you may need to provide a written request or prove your identity in other ways to ensure security. We may require verification of your identity before processing your request. We undertake to review and process your request within [15] working days from the date of receipt of your request under paragraph 1 above.
3. In the following cases, according to the requirements of laws and regulations, we will not be able to respond to your request:
(1) Related to our performance of obligations stipulated by laws and regulations;
(2) Those directly related to national security and national defense security;
(3) Those directly related to public safety, public health, and major public interests;
(4) Directly related to criminal investigation, prosecution and trial, and execution of judgments;
(5) We have sufficient evidence to show that you have subjective malice or abuse your rights;
(6) In order to protect your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain my consent;
(7) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
(8) Infringement of trade secrets;
Constrained Information System Automatic Decision-Making
In some business functions, we may only make decisions based on non-human automatic decision-making mechanisms, including information systems, algorithms, etc. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us to explain and we will provide appropriate remedies.
8. How to contact us
1. If you have any questions, comments or suggestions about this Privacy Policy or your personal information, please contact us by calling our customer service number 021-68580569 or online feedback and other methods.
2. We have set up a dedicated department for personal information protection (or personal information protection specialist), you can send an email to kefu@snmi.cn
way to contact it.
3. Under normal circumstances, we will reply within [15 working days]. If you are not satisfied with our response, you can also file a complaint with the consumer protection department or file a lawsuit with a court of competent jurisdiction.
Shanghai Shufei Technology Co., Ltd
Address: Room 310, No. 2588, Changyang Road, Yangpu District, Shanghai
September 23, 2021