Effective Date: [27] Date: [8] 2024
As the operator of the [aoGen product] products and services, Hangzhou Ao Chuang Guang Nian Internet Technology Co., Ltd. ("we") is well aware of the importance of personal information to you. We will protect your personal information and privacy in accordance with the laws and regulations. We will collect and handle personal data of individuals and comply with the requirements of the Virginia Consumer Data Protection Act ("VCDPA") and its regulation(s). In this policy, "personal data" shall have the meaning ascribed to it in the VCDPA. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the VCDPA or other laws. Any transfers of personal data to a territory outside of Virginia will be made in accordance with the VCDPA and we will take steps to ensure a standard of protection to personal data so transferred that is comparable to the protection under the VCDPA. We have developed this Privacy Policy and wish to inform you of the following so that you can make appropriate choices:
- This Privacy Policy describes how we handle your information in various scenarios.
- When you use or activate the relevant functions, use services or otherwise meet organizational and management needs of our client, we collect and use relevant information as may be necessary to achieve the functions or services or to meet organizational and management needs. Unless it is necessary in order to achieve your business functions or is required by laws and regulations, you may refuse to provide such information without affecting other functions or services.
- This Privacy Policy applies to the products and services of the [aoGen product], including the services made available through the website (the [aoGen product]) and all other products and services provided by us and covered by this Privacy Policy (collectively referred to in this Privacy Policy as "the Service" or "the [aoGen product]"). This Privacy Policy does not apply to the services provided by other third parties to you. You shall, before choosing to use the service of any third party, fully understand the product functions and privacy policy of the third party service and then choose whether to use the corresponding functions or services. We shall not be liable for any third party who may improperly use or disclose the information provided by you.
- As a user of the [aoGen product], if you use the technical services of the [aoGen product] to provide services to your users, you shall separately agree with your users on a privacy policy or similar legal documents in accordance with applicable laws.
- Relevant identities under the Service shall be defined as follows:
- "Client" means a legal person or other organization that registers an account for the Service, sets up an organization and enjoys management authority by authorizing a natural person to register the Service. The Client may invite any individual to join its organization and become its Authorized User.
- "Authorized User" means a natural person authorized or invited by the Client to join the organization set up by the Client in [aoGen product] and use the Service, including the founders and administrators of the organization. A natural person designated by the Client to configure the Service and exercise back office management authority on behalf of the Client shall be referred to as an administrator (for the avoidance of doubt, "Client's administrator" in this Privacy Policy); a natural person who initially creates an organization on behalf of the Client shall be referred to as an organization founder.
- "Individual User" means a natural person who registers and uses the Service in his or her personal capacity as an Authorized User.
Individual Users and Authorized Users are collectively referred to as "you".
We will describe below in detail how we collect, use, store, transfer (where applicable) and protect your personal information. In addition, we shall help you understand the methods to query, copy, delete, correct and withdraw authorization of personal information. As this Policy is closely related to your use of our service, it is recommended that you carefully read and fully understand all of this Policy and make any choices you deem appropriate. Please pay particular attention to the capitalized portions.
- How to Collect and Use Personal Information for This Service
- How do we use cookies and similar technologies
- Partners Involved in the Process of Using Data and Personal Information Transferred and Publicized
- How do we store personal information
- How do we protect the security of personal information
- Management of Your Personal Information
- Minors Clause
- Privacy Policy Amendments and Notifications
- Contact us
- Miscellaneous
How to Collect and Use Personal Information for This Service
In order to provide the Service to you and your customers, maintain the normal and safe operation of the Service and optimize the functional experience of the Service, during the period in which you use [aoGen product] services, we may acquire your information in the following three ways:
- Information that you provide to us initiatively during the period when you use our products and/or services, such as the relevant information filled out by you or your authorized person in cases of registration of account number, purchase of technical service, etc.;
- Relevant information that we collect proactively during the period in which you use our products and/or services, such as operation records or other log data of the applications that you use the [aoGen product];
- Under special circumstances, you may entrust and authorize our employees or partners to upload or submit relevant information on your behalf. For example, you entrust our customer service staff to assist you in uploading or submitting information.
The following two kinds of personal information that we need/may need to collect and use in connection with your use of the applications of [aoGen product] include:
- Any other information that you authorize us to collect and use as necessary in order to implement the basic functions or services of the [aoGen product] we are offering you. If you refuse to provide the relevant information, you will not be able to use the [aoGen product] normally.
- In order to implement the additional functions or services of the [aoGen product] we are offering you, you may choose to individually agree or disagree with our collection or use of such information. If you refuse to provide such information, you will not be able to normally use the relevant additional functions or achieve the functional effects that we intend to achieve, which will not affect your use of the basic functions of the [aoGen product].
[aoGen product] We are committed to building various functions or services over time in order to meet your needs. We hereby specially remind you that: due to the numerous types of functions or services provided to you by the application of [aoGen product], and different users may choose to use the specific functions or services, the basic functions or additional functions and the corresponding types and scope of information collected or used may be different. The specific functions or services shall prevail.
[aoGen product] may collect and use the personal information provided unsolicited or authorized by you when you register for and use the Service, as well as the personal information generated when you use the Service, for the following purposes and in the following manner:
Registration and Login
- When you register for and login to the Service, you are required to create an account with [aoGen product] by your [e-mail address], and you may perfect relevant online identification information (photo, nickname, password). Such information is collected to assist you to complete the registration. [E-mail address is necessary information for the implementation of the national laws and regulations regarding online real-name system. If you do not provide your e-mail address for registration and login, we may not be able to provide the Service to you.] After you register and login your account, you may fill out personal data (name, photo, etc.), and we will collect such personal data actively filled out by you for display to other users. If you only browse to the official website of the [aoGen product], you are not required to register an account with the [aoGen product] and provide the above information. We may also store your details based on business contact information that you provide to us or that we collect from your business/organization, our business partners or suppliers.
- [Based on our cooperation with telecom operators, when you choose to use "one-key login" to quickly login with the [aoGen product], upon your consent, we will use the function provided by the telecom operator, to which the mobile phone number in your device will be used as your registration account and login account and the verification of password or dynamic verification code is exempted, so as to provide fast registration and login services for you. If you do not want to use the "one-key login" function, you may register and login with the [aoGen product] by other methods.]
- If you are an authorized user, you shall be aware that your [email] may have been provided by the client to [aoGen product] at the time of sending an invitation to you, but your account identity under the said organization will be activated only when you confirm your acceptance of the invitation. If you apply to join an organization on your own initiative, your account identity under the said organization will be created when your application is approved and will be activated after you log in.
- When you register for the Service on behalf of the client, you shall also provide the name of the business/organization, type of industry, scale of employees and other relevant information. If you want to obtain more functions and rights, you are required to provide, on behalf of the client, the information of legal representative, authorized representative or other types of managers, authorization letter and other basic information in order for us to help the client complete the certification. You acknowledge that you have the full authority of such client to sign and agree to this Privacy Policy in its entirety.
- We understand that the information you provide to us may contain personal information of others, in which case you shall obtain lawful authorization from others before providing such information to avoid improper disclosure of the personal information of others.
- We only permit one account per user and if you try to create multiple accounts or violate our fair usage policy, we reserve the right to remove your data and ban & restrict your access to our service.
Message Notice
- You understand and agree that, your contact information (including but not limited to: mobile number, e- mail address) provided by you in the process of using the Service will be used for your registration, login and binding accounts, and we may send various kinds of notices to one or more of them in operation for such purposes as user message notification, identity verification, security verification, user experience research, etc. In addition, we may also provide you with related services, functions or events by text messages and phone calls. But please rest assured that, if you do not wish to receive such information, you may do so through the cancellation method specified in the applicable message or by contacting us directly.
- You are free to choose whether to participate in any marketing activities held by us. If you choose to participate, you may be required to provide your name, address, contact information, beneficiary bank account number and other information as required for the activity. Such information contains sensitive personal information and is necessary to enable you to receive funds transfers or gifts. You may refuse to provide such information and we will not be able to transfer funds or deliver gifts to you.
- In order for you to enjoy our personalized or preferential services, we may also show you, by way of text message, telephone, or push commercial or other information about services, functions, or activities that may be of interest to you through a reasonable frequency of pop-up windows. If you do not wish to receive our commercial or other information regarding goods or services, you may unsubscribe or close your subscription by using the unsubscribe method provided in text message, email or by contacting our customer service directly. If you wish to turn off this pop-up window, you may choose to turn it off by clicking the "Skip" button on the pop-up window or other relevant buttons.
Safe Operation
Operation and Safety Assurance
- We are committed to providing you with safe and trustworthy products and using environments, and providing high quality and reliable service and information is our core objective. In order to maintain the normal operation of our services and protect you or other users' or the public's legitimate interests from damage, we will collect any information necessary for maintaining the safe and stable operation of our products or services.
- We are committed to processing your personal data in accordance with the VCDPA. We will not process personal data in a manner that is incompatible with the purposes for which it was collected or for which you have provided consent, unless otherwise authorized by law. We will take reasonable measures to protect the confidentiality, integrity, and accessibility of your personal data.
- If we share your personal data with third parties, we will ensure that such third parties adhere to data protection standards that are comparable to those required under the VCDPA. Any transfer of your personal data to entities outside of Virginia or the United States will be conducted in compliance with the VCDPA and other applicable laws.
Equipment Information and Log Information
- To ensure the safe operation of software and services, the quality and efficiency of operation, ensure a safe operating environment and identify abnormal account status, protect you or other users or the public from damage to personal and property, prevent as much as possible security risks such as phishing websites, fraud, cyber-vulnerabilities, computer viruses, cyber-attacks, cyber-intrusions, and identify non-compliance of laws, regulations or related agreements or rules on [aoGen products], in the course of your use of the Service, we may use your account information, your device information, relevant web logs and the information legally shared by our affiliates or business partners in order to determine the risk of your account and transactions, for identity verification, for detection and prevention of security incidents, and take necessary recording and disposal measures according to law. If you refuse to allow us to collect the above information, we will not be able to provide the Service to you. In order to do so, we may collect from you: hardware model, operating system version number, device identifier (including, without limitation, IMEI, AndroidID, OAID, IMSI, ICCID, GAID, MEID; different identifiers may be different in expiration date, user-resettable capability, and acquisition methods), network device hardware address (MAC address), IP address, WLAN access point (such as SSID, BSSID), Bluetooth, base station, software version number, network access method, type, status, network quality data, operation, use, service log, pages you visit, your settings in the Service, crash log and password.
- We may use your account information, device information, service log information and other information that may be provided by our affiliates or business partners with your authorization or in accordance with the law in order to determine the security of your account and transactions, conduct identity verification, identify illegal circumstances, detect and prevent security incidents, and take necessary recording, analysis and disposal measures according to law.
User Feedback and Personal Information Statistics
- When using the Service, you can give feedback on problems encountered in the use process and your experience with the Service, helping us better understand your experiences and requirements when using our products or services, and helping us improve our products and services as we help you solve problems. To do this, we record your contact information, web interaction, marketing preferences, information used to investigate malicious activities, questions or suggestions received from you, records and relevant contents of your correspondence/calls with us (including your account information, work order information, or other information you provide to prove relevant facts, or other contact details you leave), information used to improve our business operations, etc, so as to enable us to further contact you and give you feedback on the progress of our handling of any issue or incident. When you request our support or assistance in [the aoGen product], you need to provide us with a description of the problem, and we will also need to collect your inquiry records, troubleshooting records and troubleshooting processes performed by the user to resolve the problem (e.g. correspondence and call records). By recording and analyzing this information, we will be able to respond more promptly to your request for assistance and use in improving the Service. If you refuse to provide the above information to Aliyun, Aliyun may not be able to provide the corresponding support or assistance which will not affect your ability to use the basic features and other products of the [aoGen product]. We may design, develop and promote new products and services based on personal information statistics. We may collect statistics on the usage of our services and services and may share these statistics with the public or third parties. However, these statistics do not contain any personally identifiable information about you.
- Please note that, any unsolicited content and information provided, uploaded or published by you when you use our products and/or services (such as product or service evaluation information published by you) may disclose your sensitive personal information. Please treat such disclosure carefully. If you disclose your personal information in messages you upload or publish in public areas visible to other users, or in responses to messages uploaded or published by others, such personal information may be collected and used by others. If you become aware of improper collection or use of your personal information by others, you can contact us via the contact information disclosed in this policy.
Change of Purpose of Collection and Use of Personal Information
Please understand that the functions and services provided by [aoGen products] may be adjusted and changed as our business develops. In principle, when new functions or services are related to existing functions or services, the personal information collected and used will be directly or reasonably related to the original purpose of processing. In circumstances not directly or reasonably related to the original purpose of processing, when we collect or use your personal information, we will notify you separately and obtain your consent in accordance with the requirements of laws, regulations and national standards by means of page prompts, interactive procedures, agreement acknowledgement and other reasonable methods.
Exceptions to Authorized Consent
Please understand that, in accordance with the relevant provisions of the VCDPA, we do not need to obtain your authorization and consent to collect and use your personal information under certain emergency circumstances
- To comply with federal, state, or local laws, rules, or regulations;
- To comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, local, or other governmental authorities;
- To cooperate with law enforcement agencies concerning conduct or activity that the controller reasonably and in good faith believes may violate federal, state, or local law;
- To protect against or prevent fraud, unauthorized transactions, claims, or other liabilities;
- To protect the security of data;
- To protect the safety or integrity of the controller's systems or business operations;
- To provide a product or service requested by the consumer or a reasonably anticipated request given the consumer's use of the controller's product or service;
- To prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any illegal activity;
- To preserve or protect the life, health, or safety of a consumer or other individual;
- To effectuate a product recall pursuant to federal or state law;
- To perform a contract to which the consumer is a party.
Situations of the Customer as a Personal Information Processor
- If you are an Authorized User, in addition to the information collected by the system or submitted by you, in order to facilitate your use of the Service, the Customer will provide to us the personal information necessary to implement and implement the functions of the Service, including but not limited to your account name, name and mobile phone number. Such information will be updated by the Customer from time to time as the case may be. According to the Customer's representation and warranty, the Customer has obtained your express prior authorization and fully informed you of the purposes, scope and methods of the collection and use of your personal information before providing the above mentioned personal information to us. If you are unable to confirm the above, we suggest that you immediately cease visiting or using the Service and to confirm the same with the Customer. You may contact us via the contact information provided in this Privacy Policy and we will provide all reasonable cooperation in our capacity to do so.
- If you are using the Service as an Authorized User, you shall be aware that the following personal information is collected by the Customer, and used, and disposed of by the Customer at the Customer's discretion, and is processed by us solely for the purpose of providing services and functions to you in accordance with the Customer's instructions and as agreed between us and the Customer ("Customer's Use Data"):
a. User name of the company you belong to; Your name, position and contact information (E-mail, mobile phone number, etc.) in the Company;
b. Member's projects, data, documents and audio/video files of the Company which are generated by you in the process of using the Service and other content information generated based on the use of the Service;
c. The Customer will also collect your IP address, operation log for network and data security purposes;
d. Other information submitted for the purposes of the organization, management and operation of the Customer, collaborative office or management of specific party teams, and required to be submitted from you. - In connection with the Customer's use of Customer Data, the Customer is responsible for informing the Authorized Users of the purposes, methods and extent of the collection and use of personal information. You acknowledge and understand that you may contact the Customer or the Customer's administrator if you have any questions or claim your personal information interests in connection therewith.
You are kindly reminded that if the information cannot be individually or in combination with other information that is personally identifiable to you, then it is not your personal information for legal purposes. If your information can be individually or in combination with other information that is personally identifiable to you, or we combine such data that we do not have a connection with any particular personal information with other your personal information, then such data, during the combination, will be handled and protected in accordance with this Privacy Policy as your personal information.
Payment for Orders
- In order to assist you to complete payment for an order, you are required to provide us with certain information relevant to completing a transaction, including information on the products and/or services involved in the transaction, the amount of the transaction, the time the order was placed, the order number, the status of the order, the method of payment, the sequence number of payment, the status of payment and other necessary information required by anti-money laundering law. We collect such information to assist you to complete transactions successfully, safeguard the security of your transactions, access order information and provide customer service etc. If you refuse to provide us with the above information, we will not be able to provide the corresponding technical service to you.
- After you complete the registration of your [aoGen product] account and purchase of the Services, if automatic billing fail to occur for any reason, the Company will issue an electronic invoice indicating that you must proceed manually, within a certain deadline date, with the full payment corresponding to the billing period as indicated on the invoice.
HOW WE USE COOKIES AND SIMILAR TECHNOLOGIES
- We use cookies and other similar technologies to enhance your experience of using the Services. When you use the Services, we may use technology to collect and store information about your access and use of the Services by sending one or more cookies or anonymous identifiers to your devices. We covenant not to use cookies for any purposes other than those described in this Privacy Policy. We use cookies and similar technologies primarily to perform the following functions or services:
- Ensure safe and efficient operation of our products and services: we may establish authentication and security cookies or anonymous identifiers that enable us to verify whether you are securely logging on to us or are victims of theft, fraud or other illegal activity. These technologies also help us to improve service efficiency and speed up login and response time;
- Make your access experience easier: using these technologies can help you eliminate the need to repeat the steps and processes required to complete your personal information and enter the content of your searches (examples: record searches, form completion).
Most browsers provide the ability for you to clear your browser's cache of data. You can manage your preferences, delete cookies or clear your data from your browser's settings menu. If you clear your data, you may not be able to use cookie -dependent services or features provided by us.
Partners Involved in Processing Data and Transfer and Disclosure of Personal Information
Partners Involved in Processing Data
Principles
Certain modules and functions of our products or/and services are provided by service providers. In order to do so, we may share certain of your Personal Information with our partners in order to provide better customer service and user experience. We will adhere to the following principles when cooperating with such partners:
- Lawful Principle: the use of data in the process of cooperation with a partner must have a lawful purpose and a lawful basis. If the partner's use of the information is no longer lawful, it should not use your Personal Information or use it again after obtaining an appropriate lawful basis.
- Proper and Least Necessary Principle: The use of data should have a proper purpose and only to the extent necessary to achieve that purpose.
- Prudent Security Principle: we will take necessary measures to safeguard the security of the Personal Information we process. We will prudently evaluate the purposes for which our partners use the data and make a comprehensive assessment of their security capabilities, and request that they comply with the legal cooperation agreement.
- The Principle of Maximization of Users' Information Right and Discretion: we will fully respect the Users' Information Right and Discretion towards their Personal Information in the process of data processing.
Entrusted Processing
We may entrust a third party with processing your Personal Information in order to authorize the third party to provide certain services or perform functions for you on our behalf. We will only entrust a third party with processing your Personal Information for a lawful, proper, necessary, specific and express purpose as stated in this Policy. The entrusted partner will only have access to the Personal Information necessary to perform its duties and we will require, in writing a written agreement between the entrusted partner and them not to use such information for any other purpose outside the scope of entrustment. For scenarios where personal information processing is entrusted, we will enter into relevant processing agreement with the entrusted partner in accordance with the laws and regulations, and will supervise the use of personal information by entrusted partner. If the entrusted partner uses your Personal Information for purposes that are not entrusted by us, it will be with your separate consent.
Joint Processing
After obtaining your express consent, we will process your Personal Information jointly with other parties. We may process your Personal Information jointly with other parties as required by laws or regulations, to the extent required for the resolution of litigation or arbitration, or pursuant to the requirements put forward by administrative or judicial authorities in accordance with the laws. For scenarios of joint processing of Personal Information, we will enter into relevant agreements with the partners and specify their respective rights and obligations in accordance with the laws, so as to ensure the compliance with the laws and regulations and the security of data in the course of use of such Personal Information.
Scope of Partners
If services provided by our Affiliates or third parties are involved in the specific functions and scenarios, the scope of partners shall include our Affiliates or third parties.
Transfer
As our business continues to develop, we may carry out mergers, acquisitions or transfers of assets, which may result in the transfer of your Personal Information. Upon the occurrence of such changes, we will continue to protect or request the successor of Personal Information to continue to protect your Personal Information in accordance with laws and regulations and with a security standard no lower than that required in this Privacy Policy; otherwise, we will require the successor of Personal Information to obtain your authorization to use such information again.
Disclosure
We will not disclose your Personal Information except as required by national laws and regulations or with your consent or active choice, or to protect the personal and property of [aoGen products], users of our Affiliates or the public. When disclosing your Personal Information, we adopt security measures that comply with industry standards.
Personal information provision and disclosure exempted from consent
Please understand that, according to the laws, regulations and national standards, we are not required to obtain your authorization or consent for provision or disclosure of your Personal Information to our partners or third parties under the following circumstances:
- It is necessary for concluding or performing a contract to which you are a party, or necessary for implementing human resources management in accordance with employment rules and regulations formulated in accordance with the law and collective contracts concluded in accordance with the law;
- It is necessary for performing statutory duties or obligations;
- It is directly related to the national security and national defense security;
- It is necessary for responding to public health emergencies or for protecting the life, health and property safety of a natural person under emergency situations;
- It is directly related to criminal investigation, prosecution, trial and judgment execution;
- Carrying out news reporting and supervision by public opinion for the public interest; Processing personal information within a reasonable scope;
- The personal information disclosed to the public by you yourself;
- Collecting personal information from legally and publicly disclosed information, such as legal news reports and government information disclosure channels; and
- Other circumstances provided by laws and administrative regulations.
HOW WE STORE PERSONAL INFORMATION
STORAGE LOCATION
We store your Personal Information collected or generated during domestic operations within Virginia, United States of America in accordance with the laws and regulations. If you use the offshore service resources (if any) of [aoGen product] for your own business purpose, your Personal Information and user business data will be transmitted abroad. In this regard, we will still adopt adequate standards to safeguard your user business data; however, since we will then conduct any processing in full accordance with your instructions, you should be solely responsible for compliance in the foregoing circumstances as the sole controller of your Personal Information and user business data.
STORAGE PERIOD
- During the time that you use the Service, we will continuously store your Personal Information and keep the same for no longer than necessary to provide the Service to you. If we cease to operate the Service, we will delete or anonymize any Personal Information we hold in accordance with applicable laws within a reasonable period of time. After you stop using the Service or switch off the Personal Information, we may delete or anonymize your Personal Information, except where:
- Data retention requirements under the laws and regulations of the jurisdictions where we provide services are complied with.
- Where a reasonable extension of time is required for financial, audit, dispute resolution or other purposes.
- If you are an Authorized User, for data controlled by the business, we will process such data according to the customer's instructions. If you have any questions or claim your personal information interests, you acknowledge and understand that you may contact the customer or the customer's administrator.
HOW DO WE KEEP PERSONAL INFORMATION SECURE
- We attach great importance to the security of your Personal Information. We have established a data security system specification and implemented technical security measures to prevent unauthorized access to and modification of your Personal Information and to avoid data damage or loss. Our network service adopts the encryption technology such as transport layer security protocol to ensure the security of your data in the process of network transmission.
- We adopt strict control on data processing authority to avoid any illegal use of data. We adopt various data desensitization methods such as code shielding to enhance the security of personal information in use. Meanwhile, we adopt encryption technology widely applied in the industry to keep your Personal Information encrypted and segregate it with data segregation technology. We always implement these technical measures and organizational management methods which may be amended or perfected from time to time in order to improve the overall security of our systems.
- Although all reasonable and effective steps have been taken and you have followed the standards required by applicable law, you understand that due to technological limitations and the possible existence of various malicious measures, it is not always possible to guarantee 100% security of information in the Internet industry, even if every effort has been made to strengthen security measures. We will make every effort to ensure the security of the Personal Information you provide to us. You are aware and understand that the systems and communication networks you use to access our services may give rise to issues due to factors beyond our control. Therefore, we strongly recommend that you take active measures to protect personal information, including but not limited to using complex passwords, changing passwords regularly and not disclosing your account passwords and other Personal Information to others.
- If we become aware of a Personal Information Security Incident in which your Personal Information is unfortunately disclosed, illegally provided or misused, we will promptly notify you as required by the laws and regulations: basic information and possible impacts of the incident, measures we have taken or will take in response thereto, suggestions for prevention and reduction of the risks at your own discretion and remedial measures against you. We will inform you of the relevant information of the incident by push notice. When it is difficult to inform personal information subjects one by one, we will publish public notice in a reasonable and effective way.
- If the operation of [aoGen products] and services is ceased, we will take reasonable measures to protect the security of your user information, including: (a) promptly cease the continuous collection of user information; (b) notify the users of the cessation notice by one-by-one delivery or public notice; and (c) delete or anonymize the Personal Information held by us.
- Once you browse or use other websites, services and Content resources, we have no ability or direct obligation to protect any Personal Information submitted during your use of third-party products, no matter you log in, browse or use such software, websites are based on links or guides to the Service, or otherwise.
Management of Your Personal Information
We attach great importance to your right to manage your personal information and make every effort to protect your rights to access, copy, correct, supplement and delete your personal information, withdraw your consent and authorization, cancel your account, file complaints and reports and set privacy functions, so as to enable you to protect your privacy and information security.
Your Right to Personal Information
Query and Correct Account Information
You can query and modify your Profile Photo and name.
Query, Correct and Delete Other Information
You can query and modify your mobile phone number and email address, and modify your login password. You can change or withdraw the scope of your authorization to us to collect and process your personal information. For the avoidance of doubt, it may not be possible for us to respond to your request for change of scope of authorization with respect to certain types of personal information, such as information necessary to fulfill the basic functions of [aoGen product] or information necessary for us to perform our obligations imposed by laws and regulations. In addition to the foregoing, if you or other competent persons have any claims, demands or questions regarding the exercise of personal information rights granted by applicable laws and regulations, you may contact us through the online customer service system or by sending an email to the contact details set forth in this Privacy Policy.
Logoff Account
- If you are an individual user, you may submit a logoff application online after logging into the system of [aoGen product].
- If you are an Authorized User, if you quit your organization or disband a team in your organization, we will delete or anonymize your personal information in such organization, provided that your personal information as an individual user of [aoGen product] will be retained. After you voluntarily logoff your personal account, we will cease to provide services to you and will delete or anonymize your personal information as required by applicable laws.
- Before logoff your account, we will verify your personal identity, security status, device information and other information and help you complete the logoff process. You acknowledge and understand that account cancellation is irreversible. After your account is cancelled, we will delete relevant information about you or anonymize your account, except as otherwise provided by laws and regulations or otherwise process data used by customers as needed by customers.
Access Privacy Policy
- You may review the entire Privacy Policy on the registration and login pages.
- Please understand that the functions of the Service as described in this Privacy Policy may differ based on factors such as the device model, system version, and software application version you are using. The final products and services you are using shall be subject to the software and services you are using.
Cessation of Operation and Announcement to You
If we cease operation, we will timely stop the collection of your personal information, notify you of the cessation of operation by serving a one-by-one notice or by posting a public notice, and will delete or anonymize your personal information we hold.
Responding to Administration Requests
For security, you may be asked to provide a written request or otherwise identify yourself before you ask us to do so. We may ask you to verify your identity prior to processing your request. In principle, we shall charge no fees for your reasonable requests; however, we reserve the right to charge a fee for repeated or excessive requests. We may refuse to provide information that is not directly related to your identity, that is a repeated application without reasonable grounds, that requires excessive technological measures (for example, to develop a new system or to fundamentally change existing practices), that risks others' legitimate rights and interests, or that is impractical. Subject to relevant legal requirements, your close relatives may exercise the aforesaid rights to access, correct, delete and copy your relevant personal information after our verification of your identity, unless otherwise arranged by you.
Exception of Responding to Request
Please understand that, according to laws, regulations or national standards, we shall have the right not to respond to your above requests in the following circumstances:
- It is necessary for concluding and performing the contract to which you are a party, or it is necessary for implementing human resources management in accordance with the labor rules and regulations formulated in accordance with the law and the collective contract concluded in accordance with the law;
- It is necessary for performing statutory duties or obligations;
- It is directly related to national security and the security of national defense;
- It is necessary in response to public health emergency or in case of emergency in order to protect the life, health and property of natural persons;
- It is directly related to criminal investigation, prosecution, trial and execution of judgment;
- We have abundant evidence to prove that you or other subjects of personal information have subjective malice or abuse of rights;
- In order to protect your or other subjects of personal information's life, property and other significant legitimate rights and interests, but it is difficult to get personal authorization or consent;
- Responding to your or other subjects of personal information will cause serious damages to the legitimate rights and interests of you or other subjects of personal information or organizations;
- Matters relating to trade secrets.
[You understand that, subject to the special circumstances imposed by the applicable laws and regulations and relevant jurisdictional standards of the jurisdictions where we provide services, we shall have the right not to respond to the above requests of you.]
Minors Clause
- [aoGen products] We are mainly oriented to adults. If you are a minor under the age of 18, before using the Service, you shall read and agree this Privacy Policy under the guardianship and guidance of your parent or other guardian and shall use our products or services and provide us with the consent of your parent or other guardian.
- If you are the guardian of a minor, if you have any questions about the personal information of the minor, please contact us through the contact information listed in this Privacy Policy.
- Company does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register for the Services. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or e-mail address. No one under age 13 may provide any personal information to Company or on the Services. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us.
- Limited by existing technologies and business models, it is difficult for us to take the initiative to identify personal information of minors in the process of registering an account. If you are the guardian of a minor and you find that we have obtained any personal information of a minor without his or her authorization, you may contact us through the contact information stated in this Policy. Upon receipt of your notice, we will verify the information and delete or anonymize the relevant information in a timely manner once it is verified to be true. If we find out the existence of the above cases on our own initiative, we will also delete or anonymize the relevant personal information.
Amendments and Notices to Privacy Policy
- The Service will be updated and changed from time to time in order to provide you with better services. We may amend this Privacy Policy from time to time. Such amendments shall form a part of this Privacy Policy and have the same effect as this Privacy Policy. Without your express consent, we will not impair any of your rights under this Privacy Policy currently in effect.
- Whenever this Privacy Policy is updated, we will send the updated version to you and will remind you of the content of the updated version by appropriate means before the updated terms take effect, so that you can understand the updated version. If you continue to use the Service after the update to this Privacy Policy, you shall be deemed to have accepted the updated Privacy Policy.
Contact Us
- Any questions, comments or requests relating to this Privacy Policy may be addressed to [contact aoGen.ai] or by mail to the following addresses: [Hangzhou Ao Chuang Guangnian Internet Technology Co., Ltd., 4/F, Tower B, Jin Xixi Business Center, Jiangcun Street, Xihu District, Hangzhou, Zhejiang Province]. In general, we will respond within fifteen business days after receipt of your relevant contact information and verification of your identity.
- As a matter of principle, we shall not charge a fee for your reasonable requests; however, we may charge a fee for repeated or excessive requests in our discretion. We may refuse to provide information that is not directly related to your identity, that is gratuitously repetitive, that would require excessive technical measures (such as the development of a new system or a fundamental change in a current practice), that would risk others' legitimate rights and interests, or that is impractical.
Miscellaneous
- In some jurisdictions, personal information may not be lawfully processed unless justified by reasonable grounds (sometimes referred to as a legal basis). The legal grounds upon which we may rely for lawful processing of personal information vary by purpose and the applicable law. This Privacy Policy may exist in several language versions. In the event of any inconsistency or conflict between the terms contained in different language versions, the simplified Chinese version of this Privacy Policy shall prevail.
- The headings herein are for convenience and ease of reference only and shall not affect the meaning or interpretation of any provision herein.