Privacy Policy
Version release date：April 14, 2024
Version effective date：April 14, 2024
Introduction
About us
Noun interpretation
How do we collect and use your personal information
How do we use cookies and similar technologies
How do we share, transmit and disclose your personal information
How do we store and protect your personal information
Your rights to manage personal information
How do we handle personal information of minors
Personal information protection of deceased users
How to update this policy
How to contact us
Dispute Resolution
1. Introduction
Welcome to use our products and services! The topic of personal
information protection has the highest priority at InnoPaaS. Therefore,we will strictly comply with laws and regulations, and take corresponding
safety protection measures to safeguard your personal information.
Based on this, the service provider of InnoPaaS (or "we") has formulated
this personal information protection policy (hereinafter referred to as
"this policy") to help you fully understand how we collect, store, use,
process, transmit, provide, disclose, delete and protect your personal
information when you are using our products and services, and how you
can manage your personal information. We aim to help you better make
appropriate choices.
Please carefully read and understand this policy before you use our
products and services, especially the terms marked in bold/bold
underline. Please ensure that your use are based on full comprehension
and agreement. Once you use or continue to use our products and
services, it means your agreement that we can use and process your
relevant information in accordance with this policy. We have tried our
best to concisely and popularly explain the professional vocabulary
involved in this policy for your understanding. If you have any questions,
comments or suggestions with this policy, you can contact us through
the contact information provided in this policy.
We may revise this policy from time to time according to laws andregulations or business adjustment. When this policy is changed, we will
show you the changed content in the form of prompt in a prominent
position, or push notices and messages after the version is updated.
Please understand that only after you confirm and agree to the changed
policy will we collect, use, process and store your personal information
according to the changed version. You are entitled to refuse the changed
version, which may prevent you from using or continuing to use our
relevant services and functions completely, or reduce the original quality
and effectiveness of services.
2. About us
The product operations and services of InnoPaaS is provided by
TRANSLAND INFORMATION GROUP LIMITED (hereinafter referred to as
“InnoPaaS”) and all of its affiliates.
Affiliates include any company or institution which is or will be controlled
by or under common control with InnoPaaS and the legal successors of
such company or institution.
“Control” refers to the ability to directly or
indirectly influence the management of the company mentioned,
whether through ownership, voting shares, contracts or other means
determined by the people's court.The basic information of our operating entity is as follows: TRANSLAND
INFORMATION GROUP LIMITED, registered office:FLAT/RM A 12/F ZJ 300
LOCKHART ROAD WAN CHAI,Hong Kong.
Generally, we collect your personal information in the following
scenarios:
Account registration and login
To create a InnoPaaS account, you need to provide us with your email
address, name and company name. If you refuse to provide the above
information, you will not be able to register your InnoPaaS account and
can only use the browsing service. Once you confirm and continue to use
this product, we will consider that you agree to our collection of the
above-mentioned relevant personal information.
You can use your password to log in to InnoPaaS. When logging in, you
need to provide us with your email address and password. We promise
that the above information is collected to provide you with account login
services, protect your account security and prevent security risks.3.Account recharge
We provide you with online recharge function by accessing the third
party payment institutions. When you recharge online through the third
party payment institutions, we will receive information about
your recharge amount.
When you recharge offline by bank transfer, you need to provide
your recharge amount, account number, bank of deposit, account name
and payment voucher.
We promise that the above information collection is only for recharge
and reconciliation. We cannot obtain your personal property information
only based on this information. If you refuse to provide it, you may not
be able to recharge your account, so that you cannot or cannot continue
to use our products, please consider carefully before choosing whether
to provide them.
4.System settings
In order to use the business alarm service provided by us, you need to
provide your name, mobile phone number, email address and company
name when setting the system. If you refuse to provide, you may not be
able to use the service. Please consider carefully before choosingwhether to provide them.
Your personal information collected indirectly from a third party
You understand that we cannot obtain the personal information you
provide to an external third party or your personal information collected
by an external third party, and we will not use unconventional methods
(such as malicious interference with the other party's data) to obtain
your personal information by software programs without
authorization. If InnoPaaS does need to collect (share, etc.) your
personal information indirectly from a third party due to the needs of
business development, and we directly or jointly provide you with
products or services, we (or the third party) will express to you the
source, type, purpose, method, business function and scope of
authorization and consent of your personal information shared before
collection (if the use method and scope exceed the scope of your original
authorization in the third party, we will obtain your authorization again) .
When some of our products or services are provided or jointly provided
by third-party authorized partners, we may indirectly collect some of
your information from some business partners and the information
about you provided by other parties when using our products and / or
services in order to conduct business necessary and reasonably.
5. How do we use cookies and similar technologiesWhen you use InnoPaaS, we will not access other similar technologies
except cookies in order to verify your identity. If you refuse to use or
delete cookies, you may not be able or continue to use our products.
6. How do we share, transmit and disclose your personal information
6.1 Share
We attach importance to the protection of your personal information.
Your personal information is an important basis and part of our products
and services for you. We collect and use your personal information only
within the purpose and scope of this policy or in accordance with the
requirements of laws and regulations, and keep it strictly confidential. In
order to provide you with more perfect and high-quality products and
services, some of our services will be provided by affiliated companies or
partners. We may share some of your personal information with
partners or affiliated companies to provide better services and functions.
We will only share your personal information for legal, legitimate,
necessary, specific and clear purposes, and will only share the personal
information necessary to provide services. If you refuse our partners or
affiliated companies to collect personal information necessary for
providing services when providing services, you may not be able to userelevant services in our products. We will not share your personal
information with any company, organization or individual other than
InnoPaaS. and its affiliates and partners necessary to complete business
functions, except for the following cases:
Sharing with your explicit and separate consent in advance: after
obtaining your explicit and separate consent, we will share your personal
information with other parties.
We may share your personal information in accordance with laws and
regulations, or in accordance with the mandatory requirements of the
competent government departments and judicial decisions.
Within the scope required or permitted by law, it is necessary to provide
your personal information to a third party in order to protect the
interests, property or safety of users or the public.
If there is sharing of personal information in actual operation, we will
inform you of the recipient's name, contact information, processing
purpose, processing method and type of personal information, and
obtain your separate consent. The receiving party shall process personal
information within the scope of the above processing purpose,processing method and type of personal information. If the receiving
party changes the original processing purpose and processing method,
we will obtain your consent again according to law.
The subjects that may share personal information in actual operation
include:
Sharing with our affiliates: your personal information may be shared with
our affiliates. We will only share necessary personal information and are
bound by the purposes stated in this policy. If the affiliated company
wants to change the purpose of processing personal information, it will
ask for your separate consent again.
Our affiliates include any company or institution controlled, controlled or
under common control with InnoPaaS now or in the future, as well as
the legal successors of the above companies or institutions.
“Control”
refers to the ability to directly or indirectly influence the management of
the mentioned company, whether through ownership, voting shares,
contracts or other ways recognized by the people's court.
Sharing with authorized partners: we may share some of your personal
information with partners to provide better customer service and user
experience. We will only share your personal information for legal,
legitimate, necessary, specific and clear purposes, and will only share thepersonal information necessary to provide services. Our partners are not
authorized to use the shared personal information for any other
purpose.
Authorized partners who may share personal information include SMS
provider. At present, our SMS suppliers include China's third-party
suppliers, China's three major operators (China Telecom, China Mobile
and China Unicom) and international suppliers. In order to send the
specified number and SMS content to the operator of the destination
country, who will finally send the SMS, we must provide your phone
number and SMS content to the SMS supplier. When your business
needs to send global SMS, your phone number and SMS content will be
cross-border transmitted, and the recipient of the information is the
operator in the destination country. In order to ensure your information
security, we will conduct cross-border data transmission through a
dedicated interface.
6.2 Transmit
We will not transmit your personal information to any company,
organization or individual, except in the following cases:
Transmit with explicit individual consent: after obtaining your individualconsent, we will transmit your personal information to other parties;
If it is necessary to transmit personal information due to combination,
division, dissolution or declaration of bankruptcy, among others, we will
inform you of the name or contact information of the receiving party.
The receiving party shall continue to perform its obligations under this
agreement. If the receiving party changes the original processing
purpose and processing method, it shall obtain your consent again.
6.3 Disclose
We will not publicly disclose your personal information. If it is necessary
to publicly disclose your personal information, we will inform you of the
purpose and type of the publicly disclosed information before public
disclosure (if your personal sensitive information is involved, we will also
inform you of the content of the sensitive information involved), and
then publicly disclose it with your separate consent. Unless otherwise
provided by laws and regulations or otherwise agreed in this policy.
For your personal information publicly disclosed, we will carefully review
its legitimacy, rationality and legitimacy as soon as we receive the
application for public disclosure, and take the strictest personal
information security protection measures and means to protect it duringand after public disclosure.
Exception of share, transmission, disclosure of your personal information
Please be aware that, in accordance with the provisions of laws and
regulations, sharing, transmitting, and disclosing your personal
information does not require your prior authorization under the
following circumstances:
Directly related to national security and national defense security;
Directly related to public safety, public health, and major public interests;
Directly related to criminal investigation, prosecution, trial, and
execution of judgments; or in accordance with the requirements of laws
and regulations, administrative agencies, public prosecutors, and other
competent agencies;
In order to protect your or other individuals' life, property and other
major legal rights and interests, but it is difficult to obtain your own
consent;Personal information is disclosed to the public by you yourself or
collected from legally disclosed channels (such as legal news reports,
government information disclosure, etc.);
Necessary for signing and fulfilling relevant agreements or other written
documents with you;
Other circumstances stipulated by laws and regulations.
7. How do we store and protect your personal information
7.1 How do we store your personal information
Information storage location.
We will store the user's personal information collected in China in
accordance with laws and regulations. If it is necessary to conduct
cross-border data transmission, we will clearly inform you separately
(including the purpose, receiver, use mode and scope, use content,
security measures, security risks, etc.) and obtain your separate consent.
The information storage period.
We promise that the storage period of your personal information is the
shortest period necessary to realize the purpose of the personalinformation handling. For example, when you use our registration and
login functions, we need to collect your password, name, e-mail and
phone number, and we need to keep your password, name, e-mail and
phone number after you provide it and during your use of the function,
so as to provide you with the function normally and ensure your account
and system security. In addition, we may save your relevant information
to the necessary period specified by relevant laws (for example, the
e-commerce law stipulates that the storage time of commodity and
service information and transaction information shall not be less than
three years from the date of completion of the transaction).
After the storage period is exceeded, we will delete your personal
information or anonymize it according to the requirements of applicable
laws.
Storage of Information Deletion.
After you cancel your account, we will delete or anonymize your
personal information. After you or we assist you in deleting relevant
information, we may not be able to delete the corresponding
information from the backup system immediately due to applicable laws
and regulations and security technology restrictions. We will safely storeyour personal information and restrict any further processing until the
backup can be deleted or anonymous.
7.2 How do we protect your personal information
We will establish an information security system and take technical
measures and other necessary measures to protect your personal
information security in strict accordance with the relevant requirements
of laws and regulations such as the personal information protection law,
the network security law and the data security law.
Our technologies and measures to protect your personal information.
We attach great importance to personal information security and take all
reasonable and feasible measures to protect your personal information:
8.Technical measures for data security.
We adopt a variety of complex data desensitization technologies and SSL
transport layer security protocol to enhance the security of personal
information in use. At the same time, we adopt BCrypt to encrypt your
login password. We have established strict data access control and
multiple identity authentication technology to protect personal
information and avoid illegal use of data. We use code security check anddata access log analysis technology to conduct personal information
security audit.
9.Other safety measures
We promote and protect your personal information security by adopting
sensitive information protection measures on the operation page.
The Internet is not an absolutely safe environment. We suggest you pay
attention to protecting the security of your personal information. Please
protect your personal information properly and provide it to others only
when necessary.
Please understand: the Internet environment is not 100% secure. We will
try our best to ensure or guarantee the security of any information you
send us. However, due to technical limitations and possible malicious
means, even if we try our best to strengthen security measures, it is
impossible to ensure the 100% security of information at the beginning.
After an unfortunate personal information security incident, we will
timely inform you of the basic situation and possible impact of the
security incident, the disposal measures we have taken or will take, the
suggestions you can independently prevent and reduce risks, and the
remedial measures for you in accordance with the requirements of lawsand regulations. We will timely inform you of the relevant information of
the event by mail, letter, telephone, push notice, etc. when it is difficult
to inform the personal information subject one by one, we will take a
reasonable and effective way to make an announcement. At the same
time, we will actively report the disposal of personal information security
incidents in accordance with the requirements of regulatory authorities.
10. Your rights to manage your personal information
We understand your concern about personal information and try our
best to ensure your right to access, correct, delete and withdraw your
authorization, so that you have sufficient ability to protect your privacy
and security. Your rights include:
10.1 You are entitled to access to your personal information.
You can consult the relevant personal information you have provided to
us according to the relevant instructions (or settings) of the products and
services we provide, include:
Account information: you can log in to your account settings at any time
through relevant product pages to access the personal data information
in your account, including your personal name, phone number, e-mail
and company name.Financial information: you can view your consumption records and
invoice records through the payment page.
Other information: if you encounter operational problems during your
visit and need to obtain other personal information that cannot be
known above, you can contact us through the way provided in this policy.
10.2 Correct / modify your personal information
When you find that the personal information you provide us has
registration errors, incompleteness or updates, you can correct / modify
your personal information in our products and services.
10.3 You are entitled to delete your personal information
You can apply to us for deleting your personal information through the
contact information publicized in this policy. Once you delete, we will
delete or anonymize such information, unless otherwise specified by
laws and regulations.
You can directly ask us to delete your personal information in case of the
following circumstances, unless it has been anonymized or otherwise
stipulated by laws and regulations:
If our handling of personal information violates laws and regulations;If we collect and use your personal information without your consent;
If our handling of personal information violates the agreement with you;
If you no longer use our products or services, or you cancel your
account;
If we no longer provide you with products or services.
After you delete the information from our service, we may not delete
the corresponding information in the backup system immediately, but
we will delete the information when the backup is updated.
After you cancel your account, we will stop providing you with products
or services and delete your personal information according to your
requirements, unless otherwise stipulated by laws and regulations.
10.4 You are entitled to rescind authorization
You can apply to us to withdraw the authorization about your personal
information through the contact information publicized in this policy.
After you withdraw your personal information authorization, you may
not be able or unable to fully use our relevant services and functions, or
you may not be able to achieve the service effect we intend to achieve.
10.5 You are entitled to cancel your accountYou can apply to us for account cancellation through the contact
information publicized in this policy. After you cancel your account, you
will no longer be able to log in and use our products and services with
this account; And all rights and interests such as the rights and interests
generated but not consumed during the use of our products and services
and the expected future interests of the account will be cleared; The
contents, information, data, records, etc. under the account will be
deleted or anonymized (unless otherwise stipulated by laws and
regulations or required by the regulatory authorities, for example,
according to the network security law of the people's Republic of China,
your network operation log will be kept for at least six months); After the
account is cancelled, it cannot be recovered.
10.6 You are entitled to obtain a copy of your personal information
You can apply to us for a copy of your personal information through the
contact information publicized in this policy. On the premise of
compliance with relevant laws and regulations and technical feasibility,
we will provide you with a copy of your personal information according
to your requirements.
10.7 You are entitled to request the transfer of personal information toyour designated personal information processor
You can apply to us for transferring your personal information to your
designated personal information processor through the contact
information publicized in this policy. We will transfer your personal
information to your designated personal information processor
according to your requirements on the premise that it meets the
conditions specified by the national network information department
and is technically feasible.
11. How do we handle personal information of minors
Our products are only for natural persons with full capacity for civil rights
and capacity suitable for their civil acts, legal persons or other
organizations. Our products do not involve the processing of minors'
personal information.
12. Personal information protection of deceased users
After the death of our user, for their own legitimate and legitimate
interests, their close relatives can exercise the right to consult, copy,
correct and delete the relevant personal information of the deceased
user through the contact information publicized in this policy, unless
otherwise arranged by the deceased user before death.You understand and confirm that in order to fully protect the personal
information rights and interests of the deceased user, the close relatives
of the deceased user who apply to exercise this right need to submit the
identity documents of the deceased user, death certificates, identity
documents of the applicant, and proof of kinship between the applicant
and the deceased user according to our designated process or customer
service prompt, and provide the types and purposes of the rights to be
exercised.
13. How to update this policy
In order to provide you with better service, we will update the terms of
this policy according to the update of products and relevant
requirements of laws and regulations. Such updates form a part of this
policy. Without your express consent, we will not reduce your rights
under this policy. Before the updated policy comes into effect, we will
notify you by reminding you in a prominent position or sending you a
push message or by other means. If such update results in a substantial
reduction or significant change in your rights under the policy, we will
ask for your separate consent again.
Major changes include but are not limited to:
Major changes have taken place in our service model. Such as thepurpose of processing personal information, the type of personal
information processed, the use of personal information, etc;
Significant changes have taken place in our ownership structure and
organizational structure. Such as owner change caused by business
adjustment, bankruptcy, M & A, etc;
The main objects of personal information sharing, transfer or public
disclosure have changed;
Significant changes have taken place in your right to participate in
personal information processing and the way in which you exercise it;
The responsible department, contact information and complaint
channels responsible for handling personal information security have
changed;
When the personal information security impact assessment report
indicates that there is a high risk.
14. How to contact us
If you have any questions, comments or suggestions on this policy, you
can contact us through any of the following ways: You can communicatewith us online through Intercom.
In addition, you understand that we will not be able to respond to your
request under the following circumstances related to personal
information:
Related to national security and national defense security;
Related to public safety, public health and major public interests;
Related to criminal investigation, prosecution and trial;
There is sufficient evidence to show that you have subjective malice or
abuse of rights;
Responding to your request will cause serious damage to the legitimate
rights and interests of you or other individuals and organizations;
Involving trade secrets;
Other circumstances stipulated by laws and regulations.15. Dispute Resolution
The interpretation of this policy and dispute resolution shall be governed
by and construed in accordance with laws of the People’s Republic of
China and Any dispute arising under or concerning this Agreement may
be litigated only in the Shanghai International Economic and Trade
Arbitration Commission and the prevailing Party shall be entitled to its
reasonable attorneys’ fees, expenses and costs incurred in connection
therewith in addition to such other relief as may be granted.
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