Vantop Technology & Innovation Co., Ltd. is a corporate organization incorporated under the laws of the People’s Republic of China (hereinafter referred to as “Vantop”). Vantop Technology & Innovation Co., Ltd. referred to in this Policy are collectively referred to as "We". We place great importance on the maintenance and protection of users' personal information. Should you have any question, opinion, or suggestion, please contact with us via firstname.lastname@example.org.
It shall be noted that this Policy does not apply to services offered to you by other third parties, which shall be subject to such third-party privacy policies.
Before using any product or service on the Vantop official website, you shall carefully read and fully understand this Policy, especially clauses marked in bold and underscored clauses. By using products or services of Vantop official website, you fully understand and agree to this Policy.
Part I. Definitions
“Vantop Official Website” refers vantop.com and its clients.
“Provider of Vantop Official Website Service” refers to Vantop, the network and software technology service provider of Vantop official website.
“Affiliates” refers to affiliates of Vantop, including its parent company, subsidiaries and branches.
“Personal information” refers to information, recorded electronically or by other means, that can be used alone or in combination with other information to identify a specific natural person or reflect the activities of such.
“Deletion of Personal Information” refers to the act of removing personal information from the system involved in the realization of daily business functions, so that it remains irretrievable and inaccessible.
This Policy has been designed to help you understand the following:
1.How we collect and use your personal information
3.How we share, assign, and disclose your personal information
4.How your personal information is protected
6.How we manage minors’ personal information
7.How your personal information is transferred internationally
8.How this Policy is updated
9.How to contact us
I.How we collect and use your personal information
The personal information we need/may need to collect and use when you use our products and/or services include the following two types:
1.You authorize us to collect and use the information necessary to perform the essential functions of providing our products and/or services for you. If you refuse to provide such information, you will not be able to use our products and/or services properly;
2.To provide you with additional features of our products and/or services, you may choose the information that we collect and use. If you refuse to do so, you will not be able to use the relevant additional features or achieve the intended functional results, but this will not affect your use of the basic functions of our products and/or services.
You understand and agree that:
1.We are committed to creating a wide range of products and services to meet your needs. Due to the wide range of our products and services and the differences in the scope of specific products/services selected by different users, the basic/additional functions and the types and scope of personal information collected and used may vary, so please refer to the specific product/service functions;
2.We are continuously working to improve our technology so as to provide you with a better experience on our products and services. From time to time, we may introduce new or optimized features that may require the collection or use of new personal information or changes in the purpose or manner in which personal information is used. To this end, we will separately explain the purpose, scope, and use of the information collected through updates to this Policy, pop-ups, page reminders, and other means, and will provide you with the means to voluntarily consent to the collection and use of the information with your express consent. Should you have any question, opinion, or suggestion in such process, please contact with us via email@example.com and we will reply you as soon as possible.
We will collect and use your personal information for the following purposes described in this Policy:
(I)Vantop User Registration
To create a Vantop account, you may be required to provide us with the following information: Your mobile phone number, email address, Vantop user name and password.
By providing of the following additional information during registration or after the account has been created, you will be helping us provide you with better a service and experience: Your name, date of birth, gender, location, and occupation. If you do not provide such information, your use of the basic functions of Vantop products and services will remain unaffected.
(II)Purchase and Delivery of Products or Services
If you purchase any Vantop products or services from us, you will be required to provide the following information to successfully complete the transaction: Identification, and payment information, as well as any receipt information as necessary to generate the order including without limitation your name, telephone number, e-mail address, correspondence address, ID card number, and credit/debit card number. You will be unable to purchase any Vantop products or services if you do not provide such information.
(III)Use of Vantop Products or Services
To ensure the normal operation of Vantop products and services, you may be required to provide us with the following information: Device geolocation and location information, device configuration information, and any text or images you have shared on the Vantop platform. We may also collect product usage logs, your IP address, and the date and time when you access our products or services. If you refuse to provide such information, we will not be able to provide you with those services. However, your use of other Vantop products and services functions will remain unaffected.
(IV)Service Quality Improvements and Personalized Ad Serving
We will collect any information you provide when contacting our customer service team, along with your answers to any surveys, and other information such as service types, how you use the services and your operations when using such services for the purpose of improving your service experience and our service quality, for risk prevention, or to recommend better or more suitable services for you. We will compile statistics and analyze such information in order to provide you with more accurate, personalized, smooth, and convenient services. If you agree, we will serve you with advertisements that you might be interested in based on the above information. If you do not want to receive such advertisements, you may unsubscribe by sending a text message or email.
(V)Analyzing Research and Development Data to Improve Our Products and Services
We invite you to join Vantop's product improvement program to help us design new products and services, and to improve our existing products and services. If you agree, we may collect the following personal information for products and services analysis and research: Your account information, device information, and diagnostics and usage data. If you choose not to join the product improvement program at this time, your use of Vantop products and services will remain unaffected.
(VI)Exceptions with authorization
You are fully aware that, in accordance with relevant laws and regulations, your personal information will be collected and used without your authorization in the following cases:
1.Circumstances relating to national security, and national defense and security;
2.Circumstances concerning public safety, public health, or major public interests;
3.Circumstances relating to criminal investigation, prosecution, trial, and the execution of a court judgment;
4.To safeguard the major legally protected interests concerning the life and property of the subject of the personal information, or of others, when it is difficult to obtain their consent;
5.When any personal information collected is information that the data subject has independently publicly disclosed;
6.The personal information collected is sourced from legally disclosed information including but not limited to, news reports, and government information disclosure;
7.When such information is deemed necessary to execute the Contract according to your requirements;
8.When the information is essential to maintain the security and stability of the products and/or services we provide, such as in the detection and correction of faults discovered in such products and/or services;
9.When the information is required for legal news reporting;
10.When the information is necessary for statistical or academic research for the benefit of the public and conducted by academic research institutions. When the results of such academic research are published, the personal information contained therein will be anonymized;
11.Any other circumstances under applicable law.
Please be aware that, in accordance with applicable laws, if we take technical and other measures necessary to process personal information in such a way that the data recipient cannot re-identify a specific individual and restore such data, or we may de-identify the information we collect for research, statistical analysis and forecasting purposes, we may use it to improve the content and layout of Vantop official website for business decision-making purposes to provide product or service support and to improve our products and services, then such use of the processed data does not require separate notification to you and your consent.
If we cease the provision of products and services on Vantop official website, we will no longer collect your personal information, notify you of the discontinuation of operations by a notice or announcement to that effect, and delete or anonymize your personal information in our possession.
When you upload or post sensitive personal information including but not limited to your race, religious beliefs, health condition, or sexual orientation via public channels when using our products or services. Please treat such sensitive personal information with care.
The foregoing information provided by you will continue to be authorized to us during your use of Vantop’s products and/or services. We will stop using and delete the above information when you cancel your account. If the law requires a longer information storage time, we will comply with such law.
The above information will be stored within the People’s Republic of China. We will conduct a safety assessment as required by applicable law if overseas data transmission is necessary.
We will seek your prior consent if we plan to use the information for purposes other than those set forth in this Policy.
We will place small files called cookies on your computer or mobile device to ensure the normal operation of the website. Cookies often contain identifiers, site names, numbers and characters. With the help of cookies, a website is able to store data such as your preferences or products added to your shopping cart.
(II)Cookies and Similar Technologies
Web beacons, pixel tags and other similar technologies may be used in addition to Cookies. For example, the email we send you may contain our website URL. If you click the URL, it will be tracked and will help us to understand your preferences for products or services and improve the service provided to you. A web beacon is often a transparent image placed in a website or an email. With the help of pixel tags placed in the email, we will be able to determine whether the email has been read or not. If you do not want your activities to be tracked in this manner, you can unsubscribe from our mailing list at any time.
III.How we share, assign, and disclose your personal information
We will not share your personal information with any other company, organization or individual except under the following circumstances:
1.To share it after obtaining your expressed consent: We will share your personal information with other parties only with your express consent.
2.We may share your personal information with other parties pursuant to laws or in response to government order.
3.To share with our subsidiaries: We may share your personal information with our subsidiaries. Only necessary personal information will be shared and it is bound by the purposes provided hereby. If the subsidiary company wants to change the purpose of the processing of personal information, we will ask you again for your consent.
4.To share with authorized partners: For the purpose provided in this Policy only, some of our services will be provided by our authorized partners. We may share some of your personal information with our partners with the purpose of providing you with better customer service and user experience. For example, when you purchase our products which are sold online, we have to share your personal information with the delivery company, so that they can arrange the delivery. Only with your personal information are we able to coordinate with our partners to provide such services. We will only share your personal information for lawful, reasonable, necessary, specific and definite purposes. And only the personal information needed by the service suppliers will be shared. Our partners are not entitled to use the shared personal information for any other purpose.
At present, Vantop's authorized partners include our suppliers, service providers and other partners. We will send the information to our global business suppliers, service providers and other partners that support us in the fields of, including but not limited to, technical infrastructure services, transaction and communication services (including without limitation payment, logistics, SMS, and mail services), service usage analysis, advertising and service effectiveness evaluation, customer services, convenient payment methods, academic research and surveys.
We will not send your personal information to any company, organization or individual except under the following circumstances:
1. To assign your information after obtaining your expressed consent; with your expressed consent, we may assign your personal information to other parties;
We will only publicly disclose your personal information under the following circumstances:
1.With your express consent or based on your active choice, we may disclose your personal information publicly.
2.If we determine that you have violated laws or regulations or seriously violated the rules of the respective agreements of Vantop official website, or for the purpose of protecting the safety or property of Vantop official website, its users or the public, we may disclose your personal information, in accordance with laws and regulations or the rules of the respective agreements of Vantop official website.
(IV)Exceptions to Prior Authorized Consent for Sharing, Transferring, and Publicly Disclosing Personal Information
Sharing, transferring or publicly disclosing your personal information does not require your prior authorized consent in the following cases:
1.Circumstances relating to national security, and national defense and security;
2.Circumstances concerning public safety, public health, or major public interests;
3.Circumstances relating to criminal investigation, prosecution, trial, and the execution of a court judgment;
4.When it is necessary to protect your or another individual's life, property or other significant legal rights and interests, but it is difficult to obtain your consent.
5.Personal information that you have publicly disclosed independently;
6.Any personal information that has been collected and sourced from publicly disclosed information, including without limitation news reports, and government information disclosure.
Subject to laws and regulations, the sharing and transfer of de-identified personal information from which the personal identity cannot be obtained by the data recipient does not constitute a sharing, transfer, and/or public disclosure and the storage and disposal of the same does not require your consent.
IV.How your personal information is protected
(I)We have adopted an industry-standard security policy to protect your personal information from unauthorized access, disclosure, use, modification, damage or loss. We will take all reasonable and necessary actions to protect your personal information. For example, when the data is exchanged between the browser and the “service” (such as your credit card data), the SSL will be used for encryption and data protection. At the same time, we use HTTPS to ensure your security when you browse the Vantop official website, Vantop shopping mall. We will use encryption technology to ensure data confidentiality. In addition, we will use reliable protection mechanisms to prevent malicious attacks on the data. Moreover, we have set up a special personal information protection department. Furthermore, we will deploy access control features to ensure only an authorized person can access the personal information. Finally, we will organize security and privacy protection training courses to enhance the employees' awareness of the importance of protecting personal information.
(II)We have a state-of-the-art data-centric, data security management system in the industry around the data life cycle, which enhances the security of the entire system from organization construction, system design, personnel management, product technology and other multi-dimensional aspects.
(III)We will take all reasonably necessary actions to ensure that inessential personal information will not be collected. We will only retain your personal information for as long as necessary to achieve the purposes stated in this Policy; unless otherwise required by laws. For example, the Law of the People’s Republic of China on Electronic Commerce requires that goods and services information and transaction information shall be retained for not less than three years from the date of completion of the transaction. Our criteria for determining the aforementioned duration include:
1.fulfilling the purpose of transactions relating to you, maintaining appropriate transaction and business records, and responding to any queries or complaints you may have;
2.ensuring the safety and quality of the services we provide for you;
3.your agreement on a longer retention period; and
4.existence of other special agreements on the retention period.
After your personal information exceeds the retention period, we will delete your personal information or anonymize the same as required by applicable law.
(IV)We strongly recommend that you do not send any personal information by email and instant messaging, or try and communicate with other Vantop users as such communications are not encrypted and the Internet is not secure.
It shall be noted that the information you voluntarily or even publicly share in using our services may involve personal information or even sensitive personal information about you or others. Please consider more carefully whether you share or even make public relevant information when using our services.
Please use a complex password to help us ensure the security of your account. We will do our best to keep any information you send us in confidence. We shall assume all liability if our physical, technical or management protection facilities are damaged, resulting in unauthorized access, breach, tampering or damage of information, resulting in violation of your rights.
(V)In the event of a personal information security incident, we will, as required by laws and regulations, forthwith inform you of the basic circumstances and possible effects of the security incident, measures we have taken or will take to deal with it, recommendations you can make to prevent and reduce the risk on your own, and remedies available to you. We will inform you of the event via e-mail, telephone, or push notification. If it is unable to notify the subject of personal information individually, we will make an announcement in a reasonable and effective manner.
Furthermore, we will also take the initiative to report the handling of user information security incidents in compliance with regulatory requirements.
You may access and manage your personal information by following ways:
(I)Access to your personal information
You are entitled to access your personal information pursuant to law. Accessing your data is possible through the following means:
Account Information – Access or edit your personal information, payment method, password, or security information, or cancel your account by clicking the relevant link on the website or in the app. For legal, regulatory, and security reasons, some information provided in your initial registration cannot be altered.
Contact us by email at firstname.lastname@example.org or through the website or app if you are unable to access your personal information.
(II)Correcting or adding your personal information
In the event you find errors in your personal information, you are entitled to request corrections. We can be contacted at any time at email@example.com or using the methods provided on the website and app.
(III)Deleting Your Personal Information
You may request that your personal information be deleted under the following circumstances:
1.We processed your personal information in a manner that violates applicable law;
2.We collected and used your personal information without first obtaining your consent;
3.We processed your personal information in a way that violates the policy agreement;
4.You no longer use our products or services or intend to cancel your account at your own; or
5.We permanently cease providing you with a product or service.
In addition, once a deletion request has been approved, we will notify and require that any other entities that acquired your personal information through our services also delete such information except where otherwise provided for by law, or unless such entities have obtained your independent authorization.
Be aware that even following the deletion of relevant data, certain applicable laws and security technologies may prevent us from immediately purging the corresponding backup information. We will securely store your personal information and isolate it from any further processing until the backup information is cleared or anonymized.
(IV)Change Your Authorization Scope
All features require certain basic personal information to function (refer to "Part I" of this Policy). You may offer or withdraw authorization to additional personal information collection at any time.
Means to withdraw authorization:
Visit the authorization page in our website or app and reset your personal information authorization status.
Following withdrawal of consent, we will no longer process the related personal information. Note, however, that your decision to withdraw consent will not affect any past personal information processing that occurred under your previous authorization.
Commercial advertisement subscriptions may be halted at any time taking the steps provided in the email or SMS.
(V)Canceling an Account that Contains a Data Subject's Personal Information
You may cancel your registered account at any time by emailing firstname.lastname@example.org.
After your cancellation of your account at your own, we will cease providing you with products or services and will delete or anonymize your personal information as required by applicable law (or at your request); unless otherwise provided by laws or regulations.
(VI)Automatic Decision Making of the Constraint-based Information System
Decisions for some functions are made using automated decision-making features, including without limitation the information system and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask for an explanation, and we will also provide an appropriate method of appeal under the premise of not violating the trade secrets or rights and interests of other users of Vantop official website, or the public interest of society.
(VII)Response to Your Request for Explanation
You may be asked to submit the request in writing or confirm your identity in other ways for security considerations. We may ask you to verify your identity before processing your request.
You also have the right to submit a complaint or report to the regulatory body governing Internet, telecommunications, public safety, and business if you are unsatisfied.
Reasonable requests will be handled at no charge, but we may charge a fee for repeated requests, or requests that exceed a reasonable limits. We may reject requests that are repeated without cause, require multiple technical approaches (such as developing new systems or radically changing existing practices), impair others' legally protected rights, or are highly impractical (such as requests that would involve data stored on backup tapes).
Pursuant to applicable law, we are unable to accept requests under the following circumstances:
1.In matters directly related to national security and national defense & security;
2.When public safety, public health, or major public interests are implicated;
3.Circumstances directly related to criminal investigation, prosecution, trial, and execution of a court judgment;
4.We find sufficient evidence that your request is made in malice or as an abuse of power;
5.Acceptance of the request may cause serious damage to the legally protected rights of either yourself or other individuals and organizations;
6.A commercial trade secret is concerned.
VI.How we manage minors’ personal information
The products, website, and services are of an adult nature. Minors are not allowed to create their own user accounts without the consent of their parents or guardians. If you are a minor, we recommend that you ask your parents or guardians to read this Policy carefully and use our services or provide information to us with consent of your parents or guardians.
In the event that a parent or guardian consents to the use of our products or services and personal information is collected from a minor, we will only use, share, transfer or disclose such information as permitted by law or regulation, with the express consent of the parent or guardian, or as necessary to protect the minor.
If we discover that we have collected personal information from a minor without the prior consent of a verifiable parent or guardian, we will manage to delete the data as quickly as possible.
VII.How your personal information is transferred internationally
In principle, the personal information we collect and generate within the People’s Republic of China will be stored within the territory of the People’s Republic of China; unless otherwise:
1.required by laws and regulations; and
2.authorized by you.
In this regard, those jurisdictions may have different data protection laws, or even no laws at all. When such is the case, we will ensure that your personal information is protected in a manner equal to the protection afforded within PRC Jurisdiction.
Our products or services are supported by resources and servers all over the world. As such, your personal information may be transferred to or accessed from a jurisdiction outside of the country/region where you use these products or services. We will implement safety assessments pursuant to applicable law before any data transfer.
VIII.How this Policy is updated
Major changes referred to in this Policy include, but are not limited to:
1.Major Changes in our service model. Such as changes in the purposes for processing personal information, the types of personal information processed, and the ways in which personal information is used;
2.Major changes in our control rights, such as changes in information controllers resulting from mergers and acquisition;
3.Changes in the main subjects of personal information sharing, transfer or public disclosure;
4.Major Changes in your rights to participate in personal information processing and the ways they are exercised;
5.Changes in the departments responsible for processing personal information, contact information, and complaints channels.
6.Personal information security impact assessment reports indicate a high risk.
IX.How to contact us
If you are not satisfied with our response, especially if our personal information processing practices have harmed your legitimate rights and interests, you may file a complaint or report to the regulatory authorities such as cyberspace administration, telecommunications, public security and administration for industry and commerce.In addition, you may seek a solution by filing a lawsuit with the competent court in Vantop’s location.