Update Date: June. 23, 2022
I. Scope of Application
Except for separate privacy policies for certain products or services, this privacy
statement shall apply to the personal information collected from our website and related products and
processed by Shenzhen pinshangyoupin Technology Co., Ltd. and its affiliates (hereinafter
referred to as “LUONENG” or “we”). We are your data controller. For the convenience of reading this
privacy statement, our website and related products are hereinafter collectively referred to as “the
Services”.
For the purpose of this privacy statement, “personal information” means a variety of
information electronically or otherwise recorded specific to an identified or identifiable natural
person separately or in combination with other information. Such personal information shall
include without limitation to the
basic
information and device information you provide or upload.
II. Personal Information Collected by
U
s
The type of personal information we collect depends upon how you interact with our
services.
1. Information you provide for us
(1) Your communications with us. When you make a request for information related to our
services, offer suggestions or opinions on our services, have the products repaired under warranty, sign
up for our marketing activities, register for understanding our current news or otherwise communicating
with us, we will collect your personal information, including your email address, phone number and
correspondence address.
(2) Questionnaire. We might send an email to the email address you’ve indicated in
registering our account to invite you to take part in our questionnaire survey. If you decide to
participate in the survey, you might be required to provide certain information, including personal
information.
(3) Interactive functions. We might provide interactive functions, including like, comment
and
repost
. We and others using our services might collect the information you submit or provide
through the aforementioned interactive functions. All information you provide in public in the above
interactive functions will be deemed “public”, not protected by the privacy protection measures
mentioned in this privacy statement. Once you use the interactive functions, the personal information
you provide might be viewed and used by third parties for their own purposes.
(4) Meetings, trade shows and other activities. We might take part in meetings, trade shows
and other activities. In these meetings, trade shows and other activities, we will collect personal
information from individuals
who
interact with LUONENG and/or service or who are interested in LUONENG and/or services. If you
provide us with any information in any of such activities, we will use such information according to our
purposes of information collection.
(5) Business development and strategic partnership. We might collect personal information from individuals and third parties to evaluate and
look for potential business opportunities.
2.
I
nformation
a
utomatic
ally
collect
ed
(1) Automatic data collection. During your use of our services, we might automatically
collect
certain information, including your IP address, user setting, MAC address, cookie, mobile
advertisements, other unique identifiers; details and location information on your browsers, operating
systems or devices (including the locations inferred based on your IP address); Internet service
providers, mobile operators; the pages you access before, during and after use of the services;
information about the links you click, how you interact with services (including your activity frequency
and duration), and other information on how you use the services.
(2) Cookie, pixel
tags
/web beacons and analytical information
.
We and third parties providing information, advertisements or other functions may use
cookie, pixel
tags
, local storage and other technologies (hereinafter referred to as “the Technologies”) to
automatically collect information through services. The Technologies are mainly small data files stored
in your devices that we and our partners use for recording certain information when you access our
services or interact with our services.
A. Cookies. Cookies are small text files stored in devices and browsers for storing prior
options. Most browsers allow you to block and delete cookies. However, the services might not work
normally if you block and delete cookies.
B. Pixel
tags
/web beacons. Pixel
tags
(also known as “web beacons”) are a string of codes embedded in the services and used
to collect information about the application of related services. With the use of pixel
tags
, we can record related information, including users’ access to specific webpages or click
of certain advertisements. We can also incorporate web beacons into our emails to confirm if the emails
are opened, processed or forwarded.
C. Analysis
.
We might collect and process the analytic information about our services by Google
Analytics or other statistical analysis tools. To know more details about how Google uses data, please
visit www.google.com/policies/privacy/partners/.You may access https://tools.google.com/dlpage/gaoptout
or choose not to use Google Analytics to collect and process the data you generate via our website.
3. Information of other sources
We might acquire information about you from other sources, including third party services
and organizations.
III. How
W
e Use
Y
our Personal Information
We will use your personal information for different commercial purposes, including:
1. Provide requested services or information, including:
• Perform the contract concluded between us and you;
• Answer questions, make comments and respond to other requests;
• Grant access to some of our services, and use certain functions and
characteristics;
• Respond to customers or their requests for technical support.
2. Management purposes, including:
• Seek lawful interests such as direct sales, R&D (including marketing research),
cyber and information security as well as fraud prevention;
• Measure interest in and loyalty to our services;
• Improve services;
• Develop new products and services;
• Ensure internal quality control and safety;
• Authenticate and verify personal identity;
• Perform audit;
• Communicate with you in respect of your account, our service activities and
modification to the privacy statement;
• Prevent activities which might be banned or illegal and file lawsuits against such
activities;
• Execute our agreements;
• Comply with our legal obligations.
3. Perform marketing for our products and services. We might customize and provide content and advertisements with your personal information.
We may provide you with such information as permitted by applicable laws. If you have any question about
our marketing practices or you don’t expect us to use your personal information for marketing, you may
contact us at
linbingcheng@psypsz.com, and let us know your needs.
4. Consent. We might use your personal information for other purposes we have clarified towards you
when you provide your personal information, or use your personal information for other purposes with
your consent.
5. Use de-identified and aggregated information. We might use your personal information and other data to
create
de-identif
ied
and/or aggregated information, including de-recognizing demographic information,
location information, information on your devices accessing our services or other analyses created by
us. The de-identified and/or aggregated information is not personal information. We may use and disclose
such information for multiple purposes, including research, internal analysis, analysis and any other
purposes permitted by laws.
6. Share content with friends or colleagues. In our services, we might provide various tools and functions. For instance, we might allow
you to provide information about your friends through our recommended services. For our recommended
services, we might allow you to forward to or share with friends or colleagues some content, including
forwarding emails to invite your friends to use our services.
7. How we use automatic collection technologies. We and third parties providing information, advertisements or other functions may use
cookie, pixel
tags
, local storage and other technologies to automatically collect information through
services. We use these technologies for several reasons as follows:
• Operation needs. We might use technologies to facilitate your use of application programs and tools using
our services necessary for identifying abnormal site practices, preventing fraudulent acts and enhancing
security, or let you use our functions;
• Performances evaluation. We might evaluate performances of our services with technologies, including performing
analysis to help us understand how visitors use services;
•
F
unctions enhancement. When you access or use our services, we might use technologies
that
may provide you with enhanced functions, which might include identifying your
identity when you register for using our services and tracking your specific preferences, interests or
previous viewed items;
•
P
ublicity or
attraction of
target audience. We might use our or third party technologies (including cross-device tracking) to provide
content in our services or on third party websites, including advertisements related to your interests.
IV. How
W
e Disclose
Y
our Personal Information
We might share personal information with the following types of third parties:
1. Service providers. We might share your personal information we collect with third party service providers. We
provide personal information for several types of service providers as follows: (i) service providers
providing services; (ii) service providers providing you with requisite information, products and other
services; (iii) marketing and advertising service providers; (iv) payment and transaction processing service providers; (v) customer service providers; (vi)
providers of IT and related services.
2. Business partners. We might provide our business partners with personal information, to provide you with
requisite products or services. We might also provide personal information for our business partners who
provide products or services together with us.
3. Affiliates. We might share personal information with affiliates of LUONENG.
4. Advertising partners. In our services, we might allow our third party advertising partners to set
technologies and other tracking tools to collect information about your activities and devices
(including your IP address, cookies, accessed pages, locations, and time of visit). When you access third party services in third party networks, the advertising partners
might use such information (and similar information collected from other websites) to send you
directional advertisements. Directional advertisements are generally called “interest-based
advertisements” or “personalized advertisements”. If you don’t expect us to share your personal
information with our third party advertising partners, you may contact us
at
linbingcheng@psypsz.com, and let us know your needs.
5. Application programming interface (API) and software development
kit (SDK). We might use third party APIs and “SDKs” as partial functions of our services. APIs and SDKs might allow third parties (including
advertising partners) to collect your personal information, in order to provide information more
pertinent to you. To know more details about our use of APIs and SDKs, please contact us based on the
following contact information.
6. Disclosure for protecting us or others. We may access, save and disclose any information we save with respect to you on condition
that we sincerely believe that it is necessary or appropriate to do so for the following purposes: (i)
comply with law enforcement or national security requirements and legal procedures, including court
orders and summons; (ii) protect your, our or others’ rights, properties or security; (iii) execute our
policies or contracts; or (iv) assist in investigating or filing lawsuits against suspicious or actual
illegal activities.
7. Disclosure at the time of merger, sales or other asset transfer.
If we are involved in merger, acquisition, financial due diligence, restructuring,
bankruptcy, takeover, asset purchase or sales, or service transfer to another provider, your information
would be sold or transferred as a part of such transactions to the extent permitted by laws or
contracts.
V. Cross-border Transmission of Personal Information
All information we process might be transferred, processed and saved in any part of the
world, including but not limited to the People’s Republic of China, India and other countries, where the
data protection laws might differ from those in your place of residence. You have understood that the risks somewhat vary under different data
protection laws. Under these circumstances, we will take measures to ensure that the data we collect
will be processed in accordance with this privacy statement and applicable laws. Besides, we warrant
that your personal information will be equally protected in the country/place where your products or
services are. For example, we will seek your approval for cross-border transfer of personal
information, or have personal information encrypted or de-identified prior to cross-border data
transfer, enter into necessary data transmission/sharing agreements with data recipients and take
other security measures.
VI. Your Options
1. General provisions. You may choose not to use your personal information under certain
circumstances.
(1) Email. If you don’t want to receive some emails from us, you may use the unsubscribe
link at the bottom of the email and
choose
not to receive such emails. Please be informed that you will still receive
transaction emails about the products or services you need. We might also send you some non-promotional
information related to us and our services. You cannot refuse to receive such information (e.g.
information related to the updates of the services, or our service terms or this privacy statement).
(2) “Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users may set in
certain network browsers. Please be noted that we will not respond to or accept transmissions marked DNT
or similar transmissions performed through network browsers.
(3) Cookies and interest-based advertisements. When permitted by the browsers or devices,
you may stop or restrict placement of technologies in your devices by adjusting your preferences, or
delete them. Please be noted that the cookie-based exit option is null for mobile application programs.
However, you may reject personalized advertisements in some mobile application programs according to the
instructions of Android and iOS.
Please be noted that you must separately choose to exit in each browser and device.
VII. Your Rights
to
your Personal Information
According to the applicable laws, you might be entitled to:
(i) Require us to confirm if we are processing your personal information;
(ii) Access your personal information or copies of your personal information;
(iii) Oppose or restrict our use of your personal information;
(iv) Require us to correct or revise inaccurate, untrue, incomplete or improperly handled
personal information;
(v) Withdraw your consent;
(vi) Require us to delete your personal information in our possession;
(vii) Cancel your personal account;
(viii)
F
ile complaints. You have the right to contact us and file complaints. We will try to reply to you within 15 business days after receiving
your complaint (or within the time limit extended as permitted by the laws of corresponding judicial
jurisdiction). If you are unsatisfied with our reply, especially when our personal information
processing prejudices your legitimate rights and interests, you may complain or report to the regulatory
departments of corresponding judicial jurisdiction, or file lawsuits with a competent court.
Except for certain exceptional circumstances stipulated by laws. If you intend to exercise the foregoing rights, please contact us
at
linbingcheng@psypsz.com.
We will process such requests according to applicable laws. To protect your privacy, we
will take measures to verify your identity before implementing your requests.
VIII. How
W
e Retain
Y
our Personal Information
Generally, we will only retain your personal information for a period specified in the
privacy statement or necessary for realizing the purposes informed in collecting such information,
except that a longer period of retention is otherwise specified by laws. Once such period expires, we
will delete
your personal information
or render your personal information anonymous.
When we discontinue our products or services in part or in whole for special reasons, we
will promptly inform you and stop collecting and processing the personal information on related products
or services. Besides, we will delete the personal information related to such products or services in
our possession or render them anonymous, unless otherwise stipulated by laws and regulations.
Please note that in the process of using the App, the App will obtain the characteristic
value of your mobile phone (Android: Android ID) as the unique identifier for your use of the App. This
information we collect serves for the account deletion function and is not used for other purposes.
IX. How
W
e Protect
Y
our Personal Information
We will take measures to safely process your information according to this privacy
statement. However, no system is 100% safe, so we cannot assure or warrant to you that all information
you offer to us will be absolutely safe. To the greatest extent permitted by the applicable laws, we
will not assume any responsibility for unauthorized disclosure.
Once you use our services or offer us your personal information, it means that you agree
that we may electronically communicate with you with respect to security, privacy and management about
your use of the services. If we
become aware
that the security system is destroyed, we might try to electronically inform you
(e.g. issuing a notice in the services and emailing you).
X. Third Party Website/Application Programs
The services might contain the links to other websites/application programs. Other
websites/application programs might mention or link to our services. These third-party services are not under our control. We strongly
recommend you to read the privacy policies of all websites and application programs interacting with
you.
XI. How
W
e Process Children’s Personal Information
The services are not specific to children who are younger than 14 (or other ages stipulated
by the local laws). We will not collect personal information from children at will. If you
are aware
that your children have provided us with their personal information without your
consent, you may contact us
at
linbingcheng@psypsz.com and inform us of your request. If we
are aware
that any child’s personal information has been collected against the applicable laws,
we will immediately take actions to delete such information and such child’s account.
XII. Update of Privacy Statement
We may decide to update this privacy statement from time to time at our own discretion. If
we have made material modifications to this privacy statement, we will inform you according to the
applicable laws. You understand and acknowledge that you will be deemed to accept the updated privacy
statement if you continue using the services after the new privacy statement takes effect.
XIII. Contact us
If you have any questions about our privacy practices or this privacy statement, or hope to
make a request for exercising the rights elaborated in this privacy statement, please contact us. The
contact information is as follows:
Shenzhen pinshangyoupin Technology Co., Ltd.
Email: linbingcheng@psypsz.com