Privacy Policy

Table of Contents

Effective Date: 1 September 2023

Introduction

Chengdu Zhijie Technology Co., Ltd. (the “Company”) understands that privacy is a fundamental human right and is committed to protecting the privacy, security, and data of its users and partners. The statements below establish the boundaries between the Company and you (the “User”) as a customer and data subject, describe our privacy practices, and explain the choices you can make and the rights you can exercise with respect to your personal data.

This privacy statement applies to all services we provide, including the Company’s physical products and the services they offer, the Company applications, and the website services.

Data We Collect

Personal information refers to all kinds of information recorded in electronic or other forms that can identify a natural person’s identity on their own or in combination with other information. The Company collects information to provide services to you, improve user experience, and send personalized notifications and advertisements. In order to provide you with Company devices or services, including responding to your inquiries, we may ask you to provide personal information. If you choose not to provide the requested information, we may not be able to provide the services you need. Most Company services are provided under a Company account. If you no longer need a service or wish to remove your data, you can delete your Company account.

Generally, the Company collects your personal information through your use of our products or services. In addition, the Company uses cookies and other technologies to collect preference information about visitors browsing the website, in order to provide a personalized experience or send personalized advertisements. If you do not wish us to use cookies, you can disable them via the cookie preferences located in the page footer. The data we collect and store from you (including the past 12 months) may include the following categories. If the collection or provision of sensitive personal information is involved, we will obtain your separate consent:

Your email address, used to identify you to our services and as the primary means of communication.
Your name, address, phone number, and other contact information, used to provide device shipping, after-sales repair, billing verification, and other services.
Your business information, including payment method and financial data (credit card, bank account, etc.), used for service or product payments, logistics tracking, and billing data.
Your IP address, unique device identifiers, referring URL, computer and connection data (such as the operating system type, device, and software information you use), access times, Internet or other network activity (such as log information used for anti-fraud, security, warranty registration, and support services).
Your account name, Internet or other network activity information (such as account logins, account activity), transaction data, and any information you provide during a transaction, or any other transaction-based content that you generate or connect to your account as a result of a transaction.
Your chat and service history with us, and any other information you may provide to us during your interactions with us.

The Company does not access (or use) files that users upload to their Company devices.

Legal Basis and Purposes

The Company will collect, use, disclose, and process (i.e., handle within the meaning of applicable laws and regulations) your personal data in the following circumstances:

With your consent.
Where necessary for the conclusion or performance of a contract to which you are a party.
Where necessary for the performance of statutory duties or obligations.
Where necessary in response to a public health emergency, or in an emergency to protect the life, health, and property of a natural person.
Where necessary to carry out news reporting, public opinion supervision, and similar actions in the public interest, and the processing of your personal information is within a reasonable scope.
Where the processing of personal information that you have made public yourself or that has otherwise been lawfully made public, in accordance with the Personal Information Protection Law, is within a reasonable scope.
Other circumstances as provided by laws and administrative regulations.

The Company will only collect, process, and use the personal information you provide for the purpose of communicating with you. Apart from the circumstances specified in the legal bases above, the Company will not disclose your data to third parties. The Company will not share your personal information with third parties for their marketing purposes. The Company will not sell your personal information to any third party.

The purposes for which we collect, use, disclose, and process (i.e., handle within the meaning of applicable laws and regulations) personal data are to manage your relationship with the Company and the Company’s services, and to achieve personalization and experience improvements so that we can serve you better when you use the Company’s services. We use and process your data for the following business purposes:

Account Management When you use our products and services, you can create login credentials or a Company account. When you create credentials with an email address and password, the system creates a unique identifier that lets you use the same credentials across our services. Depending on the services you enjoy, the information associated with your credentials or account may also include shipping addresses, payment information and history, details of purchased and connected devices, device and connection settings, device-service usage data, and your preferences for offers and recommendations provided by the Company.
Customer Experience We will provide you with a seamless customer experience by: maintaining the accuracy of contact and registration information; providing comprehensive customer support through multiple media, including online messaging and chat centers; communicating with you about products, services, subscriptions, and features that may interest you; and inviting you to participate in contests, outbound satisfaction calls and surveys, customer incentives, benefits, and loyalty rewards. We also use your data to provide a tailored experience, so that you receive personalized Company services and communications, and to make recommendations based on your use of Company services.
Transaction Support Assist you with transactions and orders for our products or services, manage your account, process payments, arrange shipping and delivery, and coordinate support, repair, and returns.
Product Support and Improvement This includes improving the performance and operation of our products, solutions, services, and support, including warranty support and timely firmware and software updates and reminders, to ensure that devices or services can continue to run.
Security Maintain the integrity and security of our website, products, features, and services, and protect against and detect security threats, fraud, or other criminal or malicious activity that may jeopardize your information. When interacting with us, we will also take reasonable steps to verify your identity before allowing you to access your personal data, such as requiring a user ID.
Service Delivery Automatic data collection is essential for providing Company services or delivering the products you need. If we cannot collect telemetry data (such as host network connection status) and personal data, we may not be able to provide some of the features we have promised to customers. We may also use automatic data collection to support and improve Company services, and to support business operations related to Company services.
Legal Compliance Comply with applicable laws, regulations, court orders, and government and law enforcement requirements, in order to properly run our services and products, protect ourselves, our users and customers, and resolve any customer disputes. The information collected may also be used to investigate security incidents and potential personal information breaches, to notify individuals and third parties of such breaches, and to prepare for litigation defense.

You have no obligation to provide any of your personal information to us. However, please note that without some of your data, we may not be able to perform some or all of the obligations under the contract we have signed with you, or to fully provide our services to you. For more information, please contact us in accordance with the instructions in the “Contact Information” section below.

Retention Period

The Company will not retain your personal information for longer than is reasonably necessary to process your data for the specified purpose. If you have consented or currently consent to our processing of your data, the period for which we will process your data will not exceed the validity of your consent. Notwithstanding the foregoing, we may retain your personal information in accordance with applicable laws and regulations, for example, to assist in any government or judicial investigation, to bring or defend a legal claim, or to use in civil, criminal, or administrative proceedings. During such retention, we will take necessary security measures and will not use the personal information for other purposes. If we do not meet the above conditions for retaining your data, we will delete and process your data in a secure manner.

Data Transfer

We may store your personal information in mainland China, and may transfer your information overseas where necessary to carry out data processing activities, such as information related to your use of our products and services as described in this Privacy Statement. If we do so, we will satisfy any applicable legal requirements to ensure that any transferred personal data remains protected and secure in the circumstances described in this Privacy Statement, where permitted by local law (including the Personal Information Protection Law of the People’s Republic of China), and where you have consented to the transfer of your personal data (if applicable).

Sharing refers to the process of transferring the control of personal information to other companies, organizations, or individuals. In principle, we will not share your personal information, except in the following cases:

Where you make a request yourself, and it meets the relevant conditions of laws, regulations, and oversight.
If we need to transfer personal information due to a merger, division, dissolution, or declaration of bankruptcy, we will inform you of the name and contact information of the recipient and require the recipient to continue to be bound by this policy. If the recipient changes the original purpose or method of processing, we will require the recipient to obtain your consent again.

Data Protection

The Company uses a variety of data protection methods to minimize the risk of misuse, unauthorized access and disclosure, and loss of access. Some of these protections include the use of pseudonymization, data encryption, data hashing, and other technical and permission control methods. When our employees directly process or access your personal information, we perform the relevant operations on a secure network and limit who can access your information through fine-grained permission control.

The Company retains personal data only for as long as is necessary to fulfill the purposes of collection. In accordance with this Personal Information Protection Policy and the data collection disclosures for specific services, we will retain your personal data for the period necessary to achieve the stated purposes, and will follow the relevant provisions of this Personal Information Protection Policy, the privacy statements of our specific services, or the requirements of applicable law.

Your Personal Information Rights

The Company’s services are provided on an opt-in basis, and the information required and collected varies by service. Except where exempted, you will have the following rights with respect to your personal information:

The right of access: You can request a copy of the personal information we have collected about you, or a specific part of it.
The right to request information about the categories of your personal information we have collected and the categories of sources from which we have collected such data.
The right to know the business or commercial purposes for which we have collected your personal information.
The right to request information about the categories of your personal information that we have disclosed to third parties and the categories of third parties to whom we have disclosed your personal information.
The right to transfer personal information: Where processing is done with your consent, or where necessary for the performance of a contract with you, you may request that we transfer your personal information directly to another data controller.
The right to delete data: You can request that we and our third-party processors delete your data.
The right to correct or change data: You can modify your contact information through your Company account. You may also ask us to change, update, or correct data that appears incorrect and that you cannot change yourself.
The right to restrict the use of data: You can request that we stop or restrict the use of all or part of your personal information (that we no longer need, that is needed to provide services to you, or that we are entitled to retain by law).
The right not to be discriminated against for exercising the above rights.

You can submit relevant requests through your Company account or our website. After we receive your request, we will evaluate it and inform you of our next steps. The Company will respond within thirty days of verifying your identity. Please note that if you exercise your rights to delete data, restrict or object to our processing, or withdraw your consent, we may not be able to continue providing you with our services because we lack the data needed for processing. In some cases, in accordance with applicable regulations, we may refuse to grant access to your data, or to modify, erase, transfer, or restrict the processing of your data — for example, if the Company is legally obligated to retain your data in order to comply with applicable law, or if your request would affect our legitimate use of data for anti-fraud and security purposes, we may also refuse your request.

You have the right to file a complaint or report with the supervisory authorities for cyberspace, telecommunications, public security, and industry and commerce, or to file an appeal with the competent authority in your location or the authority responsible for processing your data.

Data from Children

The Company’s products and services are intended for the general public and are not specifically designed for use by children under the age of 14 (or the equivalent age under the law of your jurisdiction). The Company does not collect date-of-birth information, nor does it use such information. Children who have not yet reached the legal minimum age must obtain explicit parental consent and confirmation before using the Company’s products and services. If the Company is notified or discovers that the data collected comes from a child below the legal minimum age, we will take steps to delete the information as soon as possible.

Changes to this Statement

The Company may revise this document as necessary to reflect updates to the statement, customer feedback, and new products or services. We will provide a brief summary of the changes made. If any of the terms modify the way we handle your data or affect your rights, we will notify you by email. If we cannot reach you directly, we will notify you by posting a notice. We recommend that you review this privacy statement regularly to understand how your data is handled.

Contact

For any questions or concerns about privacy, or for any requests related to your rights concerning personal information, you can contact us directly by email at hi@sudo8.com.