ZegoDealer Privacy Policy

Dear ZegoDealer users,

We have updated the ZegoDealer Privacy Policy. In this round of updates, we have made a great number of adjustments conducive to the protection of your personal information by making clear the types, manners and purposes with respect to our collection, use and sharing of personal information due to our provision of products and/ or services.

This Privacy Policy contains important information. Please carefully read the ZegoDealer Privacy Policy (especially those contents in bold font). If you have any questions, please feel free to contact us. Our contact details are set out in Section I below.

ZEGO BIRD COMPANY LIMITED ("we", "us" or "our") attaches great importance to the protection of users' privacy and personal information. We collect and use your related information when you use our products and/or services. This ZegoDealer Privacy Policy (the "Policy") explains to you how we and other members of the ZegoDealer group collect, use, save, share and transfer information when you, or in the case of business users any individuals acting on your behalf (your “Personnel”), use our products and/or services, and the way we provide for you to visit, update, delete and protect that information.

References to Personnel below are relevant only to business users’ use of ZegoBrid.com. Any references to “your” personal information shall be read as references to Personnel personal information for business users.

The Policy explains the following:

A. How we collect and use your personal information

B. Purposes for collecting your personal information

C. How we share, transfer or make available your personal information

D. How we protect your personal information

E. Personal information preservation and retention

F. How to manage your personal information and your rights

G. Protection of minors' information

H. Notices

I. How to contact us

The Policy is closely related to services made available to you by ZegoDealer and various business functions included in the foregoing services ("our products and/or services"). Before using our products and/or services, you are kindly requested to read the Policy carefully, ensure that you fully understand it and, in the case of business users, provide of a copy of the Policy to your Personnel so that they understand how we may use their information. The Policy tries to apply clear and concise terminology and provides links to further explanations for your better understanding.

If you have any questions about the Policy or related issues, you can at any time email us at Zego@ZegoBrid.com or contact us otherwise using the details set out at Section I below.

A. How we collect and use your personal information

Personal information refers to various information that is recorded electronically or otherwise and can be used alone or in combination with other information to identify a specific natural person or reflect the activities of such a person.

The personal information that we collect will include:

· basic information (including name, address, personal phone number);

· identification information (Optional);

· network identification information (including system account, IP address, PIN and password, passphrase);

· personal property information (transaction and consumption records, products of interest, balance, coupons, game exchange code, invite code and other virtual property information);

· address book, where you have allowed us to access these details;

· personal Internet access records (including software usage records, click records);

· information on common equipment (including hardware model, device MAC address, operating system, unique device identification code of software list (such as information indicating common equipment with IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information, etc. included);

· location information (including itinerary, precise positioning, accommodation, latitude and longitude, etc.) where you have allowed us to access these details;

Please understand that the functions and services we provide to you are constantly updated and developed. If a function or service is not in the above description and your information is collected, we will explain to you the type of information, the scope and the purpose of the information collection by means of page prompts, interactive processes, website announcements or other ways, to obtain your consent.

B. Purposes for collecting your personal information

Our products and/or services include a number of core functions, which contain those necessary for online shopping, necessary for improvement of our products and/or services, and those necessary for protecting the security of transactions. These functions may not be made available to you before we collect, store and use the following information related to you. If you do not provide the relevant information, you will not be able to enjoy the products and/or services we provide.

We will only collect and use your personal information for the following purposes:

1. Functions necessary for online shopping

· Registration

You need to register a ZegoDealer account to become a ZegoDealer user. When you register, you need to at least provide us with your desired ZegoDealer account name and password, your own mobile phone number. We will verify your identity by sending a SMS verification code. You can modify and supplement your gender, date of birth, and district information , which belongs to your "account information". Your additions to the account information will help us recommend products to you on a personalized basis and provide you with better shopping experience. However, if you do not provide this additional information, it will not affect the basic functions for your online shopping.

· Display and search

To enable you to quickly find the products you desire, we collect information on the device via which you use our products and/or services (including device name, model, ID, operating system and application version, language settings, resolution, service provider network ID (PLMN)) and the browser you use, so as to display product in the best way. We will also use your personal information above in order to continuously improve and optimize the above functions.

You can also search to find exactly what you need. We will keep your search history for you so as to avoid repeated input or to show products associated with those you have searched for before. When your search records are combined with your other personal information, we will treat it as your personal information and process and protect in accordance with the Policy.

· Ordering

When you are ready to buy the products in your shopping cart, ZegoDealer will generate an order for you. You need to fill in at least the consignee's name, delivery address and mobile phone number in the order. At the same time, the order will state your real name information or company name, the order number, the goods or service you intend to buy, the price you should pay, and the terms of payment.

All of the above information constitutes your "order information". We will use your order information to conduct your identity verification, complete the transaction, payment, settlement and delivery, retrieve your order for you on our system (for example if you call us), and provide customer services and after-sales services for you; we also use your order information to determine if there is an exception in your transaction to protect your transaction.

· Payment

After your order is placed, you can make payment in a manner provided by ZegoDealer Affiliates or any third party payment institutions (including OnePay, etc., collectively, "payment institutions").The payment function itself does not collect your personal information, but we need to share your ZegoDealer order number and transaction amount with these payment institutions so that they can confirm your payment instructions and then make payment. "Affiliate" means any company or agency that currently or in the future controls a party, is under the control thereof, or under the common control with that party as well as the legal representatives of the foregoing companies or agencies. "Control" refers to the ability to influence, directly or indirectly, the management of the companies referred to, whether through ownership, voting shares, contracts, or other forms recognized by the people’s courts.

· Delivery

After you place an order and choose cash on delivery or make payment online, ZegoDealer's affiliates or third-party delivery companies that cooperate with ZegoDealer (hereinafter referred to as "delivery companies") will deliver for you. You acknowledge that ZegoDealer's affiliates or third-party delivery companies in cooperation with ZegoDealer will use your order information to ensure that your ordered products can be safely delivered.

We will use your mobile phone number method to verify your identity. Please note that our couriers all are subject to ZEGODEALER's confidentiality system.

· Customer services and after-sale services

To activate our telephone customer services and after-sale services, we will use your account information and order information.

To ensure the security of your account, our staff in the call center and online customer services will use your account information to verify your identity with you. When you need us to provide customer service and after-sale services related to your order information, we will check your order information. You will be required to provide information other than the above when communicating with our customer service staff, such as when you request us to change the delivery address, contact person or contact number on your account.

2. Functions necessary for improvement of our products and/or services

We may use your order information, browsing history, hobbies we collected so as to show you the products or services you are interested in; or suggest what you might want to find while you search. We also obtain other reasonable information on you for the purpose of providing and improving services, including the relevant information that you provided to us when you ask for customer services, and the relevant information that we obtain when you interacted with our Affiliates and partners. We associate your various devices with each other, so that we can combine information obtained from each of them to provide you with a consistent service across all these devices. We also combine information from your use of one service with that from other services so as to provide you with services, personalized content, and recommendations.

3. Functions necessary for protecting the security of transactions

To enhance the security of your system when using our products and/or services, to accurately prevent phishing website fraud and to protect account security, we judge risks about the use of your account via information on your browsing, orders, your frequently used software, and devices and record some links ("URL") that we believe to be risky; we also collect information about your device to analyze the ZegoDealer system, conduct traffic statistics and investigate possible risks, and troubleshoot when you choose to send us abnormal information.

4. To enhance your shopping experience on ZegoDealer

To make your shopping more convenient or more fun, so as to enhance your online shopping experience in ZegoDealer, we collect and use your personal information for the following additional functions.If you do not provide this personal information, you may still be able to shop online, but you cannot use these additional functions that can improve your shopping experience, or you may need to repeatedly fill in some information when purchasing certain products. These additional functions are:

· Personalized recommendations based on location information

We will collect your location information to judge your location and automatically recommend products or services related to your area. We only collect your geographic location in real time for product and service recommendation purposes, and do not combine it with other information to store details of your whereabouts.

· Camera-based additional functions

With this function, you can shoot videos, take pictures, scan code.

· Additional functions based on pictures uploaded

You can upload your photos in ZegoDealer to shop, share and evaluate products. We will use the photos you uploaded to identify the products you need or use comments that contain the photos you uploaded.

· Additional functions based on address book

We will collect your address book information so that you don’t have to manually input the information in the contacts in your address book when shopping.

The above additional functions may require that you allow us to access to your geographic location (location information), camera (camera), photo album (image gallery), microphone, and address book so that we can collect and use the information necessary for these functions. You can check the opening status of your above-mentioned permissions item by item in your phone setting. If you make them unavailable, we will no longer continue to collect and use the personal information, nor can we provide you with the above-mentioned features corresponding to those authorizations. However, your decision to opt out of these functions will not affect the processing of personal information previously conducted.

5. Other purposes

We will also collect and process your personal information in the following circumstances:

· where requested by public authorities in furtherance of their powers or functions, including for national security, public safety, public health and major public interests;

· relating to criminal investigations, prosecutions, trials and execution of judgments;

· for the purposes of protection of material legal rights and benefits such as the lives and properties of the personal information subject or other individuals where it is difficult to obtain the consent of the subject involved;

· the personal information to be collected is made available by the subject of the personal information to the public;

· your personal information is collected from legally disclosed information, such as legitimate news reports, government information disclosure, etc.;

· necessary for signing a contract as required by you;

· necessary for maintaining the safety and stable operation of our products and/or services, such as the detection and resolution of any faults with products and/or services;

· required for legal news reports;

· necessary for academic research institutions to conduct statistical or academic research for public interest, to the extent that the personal information contained in the academic research or description results is de-identified;

· other circumstances stipulated by laws and regulations.

Rules for the use of your personal information

1. We will use the personal information collected in accordance with the Policy and to provide our products and/or services.

2. After collecting your personal information once we no longer need it to provide services to you, we will anonymise the data through technical means. One cannot identify you from anonymised information. Please understand that in this case we have the right to use information that has been anonymised and to analyze the user database and use it commercially subject to non-disclosure of your personal information.

3. When you deregister, we will stop using and delete your personal information.

4. We will generate statistics on the use of our products and/or services and share this statistical information with the public or any third parties to demonstrate the overall trends of our products and/or services. However, these statistics do not include any of your identity information.

5. When we display your personal information, we will desensitize your information by content substitution and anonymization to protect your information.

When we intend to use your personal information for other purposes not specified in the Policy, or use the information collected for a specific purpose for other purposes, we may notify you by email, pop up notice or any other means available and meeting any other requirements required of us by law.

C. How we share, transfer or make available your personal information

We will share, transfer or make available your personal information as follows:

1. We share your personal information with our affiliates. However, we only share it on a need-to-know basis and will be bound by the purposes stated in the Policy. If our affiliates are to change the intended purposes for which they use your information, they will notify you in advance and seek your consent if necessary.

2. We share your order, account, device and location information with partners and other third parties to ensure the smooth completion of our services. However, we will only share necessary personal information for the purposes set out in Section B. Our partners have no right to use the shared personal information for any other purposes. Our partners include:

· Suppliers of goods or technical services

We share your personal information with third parties supporting our functions. These third parties provide the following types of support to us: infrastructure technical services, logistics and distribution services, payment services, professional advisory services, and data processing for us. The information is disclosed to make available the core functions of our products and/or services. For example, we must share your order information with a logistics service provider to arrange delivery; or we need to notify a third party payment institution of your order number and transaction amount so that it can confirm your payment instructions and then make payment.

· Third-party merchants

We share your order information and other necessary information about the transaction with a third-party merchant where required to effect your purchase of goods or services, and to enable it to complete the follow-up after-sale services.

· Partners who commission us to promote

Sometimes, we market other companies to users of our products and/or services. We share your indirect user image formed based on your personal information in combination with non-personal information with the partner who commissioned us to promote (the "client"). However, we will only provide information on the coverage and effectiveness of the promotion to the client rather than your personal identity, or we will aggregate this information so that it does not identify you. For example, we can tell the client how many people saw its promotional information or purchased its products with the marketing information, or provided them with statistical information that could not identify personal identity to help them understand its audience or customers.

3. We will transfer your personal information to companies, organizations or individuals, for mergers, acquisitions, asset transfer, or similar transactions; if personal information is involved in the transfer. We will require companies and organizations that receive your personal information in this context to be bound by the Policy. Otherwise, we will require them to ask for your permission again.

4. In order to comply with laws, enforce or apply our conditions of use and other agreements, or to protect the rights and property or safety of ZEGODEALER, you or other ZegoDealer customers, such as preventing fraud and other illegal activities and reducing credit risks, we will exchange information with other companies and organizations. However, this does not include selling, renting, sharing or otherwise disclosing personal information for profit making purposes in violation of the commitments made in the Policy.

5. Public disclosure

We will make available your personal information to the public only under the following conditions to the extent that security measures generally accepted in the industry have been taken:

· At your request, and limited to the personal information you designate in the manner you have requested;

· As required by laws and regulations, mandatory administrative enforcement or judicial orders, we may publicly disclose your personal information of the required type in a manner requested. Subject to laws and regulations, when we are requested to disclose, we will require the corresponding legal process documents, such as summons or investigation letters. All requests are carefully reviewed to ensure that they are legal and we will only disclose the data that the law enforcement agencies have legal right to obtain for specific purposes. As permitted by laws and regulations, we will disclose documents under the protection of encryption keys.

For companies, organizations and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requesting them to process personal information by taking relevant confidentiality and security measures in accordance with our instructions and this Policy. In the use of personal sensitive data, we require third parties to adopt data desensitization and encryption technologies to better protect user data.

D. How we protect your personal information

We value personal information security and will take all reasonable and practical measures to protect your personal information. That said, the Internet is not absolutely secure. Communication methods with other users, such as e-mail, instant messaging, and social software, cannot be fully encrypted. We recommend that you use complex passwords when using such tools, and take care to protect your personal information.

We set out below the security measures taken to protect your personal information:

1. Data security technical measures

We will take appropriate technical and organizational security protection measures, including reasonable systems and security technologies, to prevent unauthorized access, modification and loss of your personal information.

ZegoDealer's network services are based on encryption techniques such as transport layer security protocols. ZegoDealer provides browsing services through https and other methods to ensure the security of user data during transmission.

ZegoDealer applies encryption techniques to save on an encrypted basis user's personal information and isolate it through isolation techniques.

ZegoDealer adopts strict data access control and multiple identity authentication technologies to protect personal information and prevent data from being used illegally.

ZegoDealer adopts code security automatic inspection and data access log analysis technology to conduct personal information security audits.

2. Other security measures taken by ZegoDealer to protect personal information

ZegoDealer manages and regulates the storage and use of personal information by establishing a data classification system, data security management specifications, and development specifications.

ZegoDealer controls data security in an all-round way through signing confidentiality agreements with those who will access to the information, monitoring and auditing mechanisms.

Strengthen safety awareness: We also hold safety and privacy protection training courses to strengthen employees' awareness of the importance of protecting personal information.

3. We only allow employees of ZegoDealer and ZegoDealer Affiliates and partners to access personal information on a need-to-know basis and set strict access control and monitoring mechanisms for this purpose. We also bind all persons who may come into contact with your personal information with confidentiality obligations. Those who fail to fulfill the obligations may be subject to legal liabilities or have their relationship with ZEGODEALER terminated.

4. We will take all reasonable and practical measures to avoid collecting uncorrelated personal information.

If you have any questions about personal information protection, you can contact us through the contact information at the bottom of the Policy. If you find that your personal information has been made known, especially your account and password, please contact us immediately through the contact information set out in Section I (How to contact us) at the bottom of the Policy so that we can take appropriate measures.

E. Personal information preservation and retention

We will hold your personal information for as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. Unless otherwise specified by laws and regulations, we will remove or anonymize your personal information within one month from the date when your account is cancelled. If the foregoing period expires, we will remove or anonymize your personal information.

If we terminate services or operation, we will notify you at least 30 days in advance and remove or anonymize your personal information after the termination of services or operation.

F. How to manage your personal information and your rights

ZEGODEALER attaches great importance to respecting your privacy rights and makes every effort to protect your right to access, correct, delete, and withdraw consent to use, your personal information, so that you have full capacity to protect your privacy and security. These rights are set out below. Where you exercise your rights, we will honor your request as required under applicable laws, but your rights are not absolute as they do not always apply and exemptions may be applicable.

1. The right to access and correct your personal information

Unless provided by laws and regulations, you have the right to access to and correct your personal information at any time, including:

· Account information Setting: if you intend to change personal information:Home - click "Me" - click head portrait for account settings - personal information;

· Delivery information Setting: For mobile App, go to the Home - click "Me " - click "my address". You can also set the most commonly used delivery address as the default one, so that when you do not change the delivery address when you purchase next time, your products will be delivered to your default address.

· Order information Setting: Home - click "Me" - My orders/To pay/orders/To rate. You can choose to delete the completed orders to delete your order information, but this may make it impossible for us to accurately determine your transaction information and therefore it is difficult to provide the corresponding after-sale services.

· Browsing information: You can access to or clear your search history, view and modify interests, and manage other data. For the mobile App: search history: Home - click "search" - " Delete" ; interests and other data: Home - click "Me" - "My likes", stores followed and Item collected ; Browse records: Home - click "Me" - "History " to clear your Activities.

· Comments: You can access to or update your personal comments On mobile App: Me – My orders/To rate – Product details page – Feedback.

· Shopping Preference: You can personally add personal information such as your wish list, favorite stores, etc. in "Me" under mobile App. This will make it easier for you to purchase related products and services, and for us to recommend products in which you may be interested. You can delete and modify your above information in this way.

Please feel free to contact us if you need to access or correct other personal information arising from your use of our products and/or services. We will respond to you in a manner and by the deadline set out in the Policy.

2. The right to request that your personal information be transferred

Subject to the limitations of applicable laws, where processing your personal information is necessary for entering into or performing our obligations under a contract with you or is processed as a result of your consent, you may have the right to request your personal information be transferred to you or another controller (where technically feasible). This is referred to as the ‘data portability’ right under the General Data Protection Regulation.

3. The right to deletion of your personal information

Subject to the limitations of applicable laws, you may request for us to delete your personal information. If we decide to respond to your request for removal, we will also notify any entity that obtains your personal information from us, requesting for removal in a timely manner, unless otherwise required by laws and regulations, or the entities are authorized by you.

4. The right to object to the processing of your personal information

Subject to the limitations of applicable laws, you may request to object to the processing of your personal information by changing the scope within which we can continue processing that personal information.

5. The right to change your authorization scope or withdraw your authorization

To the extent you have given us authorization to collect and process your personal information, you may withdraw that authorization to process your personal information for certain purposes by deleting information, turning off device functions, or changing privacy settings on ZegoDealer website or in the software. You can also withdraw your authorization granted to us by deregistration so that we cannot continue collecting your personal information.

Please understand that each business function requires some basic personal information. Once you withdraw your consent or authorization, we cannot continue providing you with the services for which you withdraw consent or authorization, and will not process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the processing of personal information previously conducted according to your authorization.

6. Right to restriction of processing

Subject to the limitations of applicable laws, you may request us to restrict our processing of your personal information.

7. Deregistration

You can apply to us for deregistration of your ZegoDealer account with Zego@ZegoBrid.com. After you deregister, we will stop providing products and/or services to you and delete your personal information as required by you unless otherwise stipulated by laws and regulations.

8. If you do not want to receive any promotional information we send to you, you can cancel it at any time by taking the following steps:

(1) We will work with third-party platforms or media ("platforms") to recommend personalized products to you based on your personal information. The personal information includes your shopping history on the site, access to the sites of ZEGODEALER’s affiliates, and interests and hobbies you have entered in your account settings. The platforms only allow us to display products. The links thereto are personalized products in ZegoDealer and managed by ZegoDealer. Therefore, we do not provide advertisers with any of your personal information. We allow you to block in the recommendation window so you can block ads that you don’t like. If you are not willing to accept ZegoDealer's recommendation services on a single platform, please contact the platform to close it. You know and understand that the platform is an entity that is engaged in business independently and not under the management of ZegoDealer.

(2) In order to protect your privacy, we will not send you any marketing information related to sensitive content such as religious beliefs, sex, illness and others to you in any manner or means.

Responding to your requests

Subject to the applicable law, you are entitled to submit the above requests as described above or otherwise by contacting us through Zego@ZegoBrid.com . We will respond to your requests without undue delay, and in any event within one month of receipt of the request, unless such request is complex in which case we may extend this period by a further two months (provided that we will inform you of this within one month of your request if so). We do not charge you for your reasonable request in principle; however, we may charge a certain amount of cost in accordance with applicable law for repeated requests that exceed a reasonable limit. We may reject those requests that are duplicative, require excessive technical means (for example, developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or that we are permitted to reject under applicable laws.

In certain situations, we may not be able to respond to your request. These situations may include situations:

· relating to national security and national defense security;

· relating to public safety, public health, and major public interests;

· relating to criminal investigations, prosecutions and trials;

· where there is sufficient evidence that you abuse the rights of others;

· where a response will result in serious damages to the legitimate rights and interests of you or other individuals and organizations.

Complaints to a data protection authority

You have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your data has arisen.

G. Protection of minors' information

ZEGODEALER attaches great importance to the protection of minors' personal information. If you are a minor under the age of 18, you must obtain prior written consent from your parent or legal guardian before using our products and/or services. ZEGODEALER protects personal information of minors in accordance with applicable laws and regulations.

For the personal information of minors collected with the consent of parents or legal guardians, we will only use or publicly disclose it when permitted by laws, explicitly consented to by the parent or guardian or required for protecting the child.

If we find ourselves collecting personal information of a minor without the prior consent of a verifiable parent or legal guardian, we will try to delete it as soon as possible.

H. Notices

This document is a notice to you and not a contract between us.

To provide you with better services and keep pace with the development of ZEGODEALER’s business, this Policy will be updated from time to time. We will remind you of the updates by releasing an updated version on ZegoDealer website and mobile terminal. We also invite you to visit ZegoDealer to keep abreast of the latest version of the Policy.

I. How to contact us

If you have any questions, opinions or suggestions about the Policy or related issues, you can at any time email us at Zego@ZegoBrid.com .