Version update tips
This version is updated: August 1, 2023
Effective date of this version: August 1, 2023
 
Based on better showing and explaining our privacy rules and your user rights to you, and providing you with better personal information protection measures, we have updated our "Privacy Policy" at the aforementioned time. The content mainly includes: update the description of the collection and use of personal privacy information by third-party SDK service providers in accordance with the latest laws and regulations. Please read and fully understand the full text before using/continuing to use our products and/or services, and use/continue to use after agreeing to all content.
Before the "Privacy Policy" of this product becomes effective, we will prompt you on a prominent position on the homepage of the product and/or service or send you a push message or notify you in other ways, so that you can choose to continue using our product and/or You can check the updated privacy policy in time before serving.
preface
Sailing Spark (hereinafter also referred to as "we") is well aware of the importance of personal information to you, so we attach great importance to the protection of your privacy and personal information, and we also include this "Privacy Policy" (hereinafter also referred to as "this policy") The content of the website is treated and processed with a high degree of prudence. This policy is closely related to our products and/or services you use. When you download, install, launch, browse, register, log in, use our products and/or services (hereinafter collectively referred to as "using our products and/or services") ”), we will process and protect your personal information in accordance with the provisions of this policy, so we hope that you can carefully read and fully understand the full text of this policy, and when necessary, follow the guidelines of this policy to make appropriate actions choose. We try our best to explain to you the relevant technical terms involved in this policy in a concise and concise manner, so as to facilitate your understanding. We hereby kindly remind you that the clauses in this policy that are (possibly) materially related to your rights and interests have been specially reminded you in bold font, please pay attention to the key points to read.
You should use our products and/or services after carefully reading and fully understanding this "Privacy Policy". You should stop accessing/using our products and/or services immediately. Your use or continued use of the products and/or services we provide means that you fully understand and agree to the entire content of this Privacy Policy (including updated versions).
If you have any doubts or other related matters in the process of reading this "Privacy Policy", you can contact us through the "Help Feedback" channel on the product function page or by dialing the manual customer service number 010-57143262; at the same time, you can also Send an email to fun@sailingspark.com or send it to us by mail. Our receiving address is provided at the end of this policy. We will answer you as soon as possible.
about Us
Sailing Spark was established in 2023. It is committed to serving Internet users as the orientation, technological innovation as the core drive, and integrating platform operation and product research and development. The company's core team has many years of experience in Internet advertising and mobile APP. Since its establishment, the company has focused on strictly selecting advertisers and traffic suppliers to ensure that both sides have high-quality resources, help the healthy development of the advertising industry, and build an honest market. Through the core algorithm developed by itself, the team closely connects and efficiently matches the three major information of advertisers, traffic, and technology, helping customers achieve precise placement and instant cash.
This "Privacy Policy" will help you understand the following
1. The scope of application of this "Privacy Policy" and the meaning of related terms
2. How we collect and use your personal information
3. How do we use cookies and similar technologies
4. How do we share, transfer and publicly disclose your personal information
5. Your right to control your personal information
6. How do we store and protect your personal information
7. Protection of minors
8. Updates to this "Privacy Policy"
9. How to contact us
10. Others
 
11. The scope of application of this "Privacy Policy" and the meaning of related terms
(1) Scope of application of this "Privacy Policy"
This "Privacy Policy" is the general content that applies uniformly to all our products and/or services. When you use any of our products and/or services (for example: SparkTv), this "Privacy Policy" applies regardless of the product and/or whether the service has a separate privacy policy, and whether you are a browsing user (guest) or a registered login user. However, please note that this "Privacy Policy" does not apply to the following situations: information collected through third-party services (including any third-party websites) directly provided by third parties accessed through our products and/or services; Information collected by other companies and institutions that provide advertising services in our products and/or services; our products and/or services may contain or link to information provided by third parties and/or third-party services (including any third-party Website), these information and/or services are operated by third parties, and your use of such information and/or services has nothing to do with us. We hereby kindly remind you that when using third-party information and/or services, you should pay attention to and carefully read the relevant user agreement and privacy policy displayed to you by the third party, and properly keep and carefully provide your personal information. This "Privacy Policy" only applies to your personal information collected by us, and does not apply to the collection of your personal information by any third party, as well as the services provided by any third party or the information usage rules of any third party. The collection, storage and use of your personal information by third parties is also not responsible; other products and/or service content provided to you by Sailing Spark.
12. How we collect and use your personal information
When you use our products and/or services, we need/may need to collect and use some of your personal information. The types of your personal information we collect and use include two types: The first type: our products and/or services Information necessary for core business functions: This type of information is necessary for the normal operation of products and/or services, and you must authorize us to collect it. If you refuse to provide it, you will not be able to use our products and/or services normally; the second type: information that may be collected for additional business functions: this information is required for non-core business functions, and you can choose whether to authorize us to collect it . If you refuse to provide it, it will result in the inability to realize the additional business functions or the effect we intend to achieve, but it will not affect your normal use of the core business functions.
We need to remind you that: Since we have many products and services, the content provided to you is also different, so the core business functions (including the type of your personal information collected by them) will also vary depending on the content of the products/services. There are differences, and the details are subject to the actual provision of the product/service. In addition, you understand and agree that we hope to provide you with perfect products and services, so we will continue to improve our products and services, including technology, which means that we may often launch new business functions, It may be necessary to collect new personal information or to change the purpose or method of using personal information. If a function or product/service that needs to collect your personal information is not described in this "Privacy Policy", we will notify you separately by updating this policy, page prompts, pop-up windows, interactive processes, website announcements, etc. You explain the purpose, content, use method and scope of the information collection, and provide you with a way to choose your consent, and collect it after obtaining your express consent. During this process, if you have any doubts or related matters, you can contact us through the methods provided at the end of this article, and we will answer you as soon as possible.
Usually, we will implement, collect and use your personal information or apply for relevant permissions for the following functions/scenarios:
(1) Video browsing functions
Our products and/or services provide you with image stitching services. During this process, we need to collect some of your information, such as: device model, device name, device unique identifier, language setting, operating system and application version, Login IP address, network access method such as wifi information, network quality data, mobile network information (including operator name), product version number, log information (such as operation log, service log), application information you installed or running process information, etc. We collect this information to improve service security, ensure operational quality and efficiency, and then provide you with our core image stitching service. If you refuse to provide it, you may not be able to use our products and services.
(2) Registration and login functions
When you use the registration and membership functions, you need to complete a series of registration (member) procedures according to our guidelines. After you become a registered (member) user, we will provide you with exclusive products and services for registered (member) users. /or service. During this process, you need to provide us with some information that identifies your user identity individually or in combination, such as: mobile phone number, verification code matching result, avatar, etc., and create an account UID. We collect this information to complete the registration (member) process, provide you with continuous and stable registration (member) services, and protect the security of your registered (member) account. You should know that the matching result of mobile phone number and verification code is your personal sensitive information. We collect this type of information to meet the requirements of relevant laws and regulations. If you refuse to provide it, you may not be able to use our function. Please consider carefully Available later.
(3) Customer service and after-sales functions
When you contact our customer service or submit an after-sales application for our products and/or services, for the security of your account and system, we need you to provide relevant personal information that matches the personal information you provided before to verify your user identity . After the verification is successful, we may need to collect your communication information with us (for example: account information, order information, pictures/videos/text information you provided to prove the relevant facts, etc.), your contact information, and in order to maintain evidence Your communication records with us, including online communication records, telephone recordings, etc., in order to solve problems for you and improve our products and/or services as soon as possible. When you use the problem feedback function in the APP, for example: the operation path in "SparkTv APP" is: My—About Us—Email Feedback fun@sailingspark.com. We may need to collect your communication information with us (for example: ssid, clipboard content,, email, mobile phone number, IP address, client version, device type, device version, operating system version) in order to solve it for you as soon as possible problems and to improve our products and/or services.
(4) Guarantee account security function
We need to collect some of your information to protect your account and system security when using our products and/or services, and help improve the security and reliability of our products and/or services to prevent any harm to users, Sailing Spark , social behavior, such as: your ssid, account login location, commonly used device information, login IP address, product version number, device version, mobile phone style, language mode, browsing history, transaction information, member real-name authentication information, network usage Habits, service failure information. Based on the above information, we will comprehensively judge your account, account and transaction risks, conduct identity verification, customer service, detection and prevention of security incidents, fraud monitoring, archiving and backup purposes, and take necessary recording, auditing, analysis and disposal measures according to law , once we detect that there is or is suspected to be an account security risk, we will use relevant information for security verification and risk elimination to ensure the security of the products and services we provide to you, so as to protect your rights and interests from infringement. At the same time, when account or system security issues occur, we will collect this information to optimize our products and services.
(5) Others
As mentioned above, if a function or product/service that needs to collect your personal information is not described in this "Privacy Policy", or we have a direct or direct relationship with the stated purpose of collecting your personal information Before using personal information within the scope of reasonable association, we will separately explain to you by updating this "Privacy Policy", page prompts, pop-up windows, message notifications, website announcements or other ways that are convenient for you to know, and provide you with self-chosen consent and collected and used with your express consent.
exceptions
In addition, you fully understand and agree that we do not need your authorization to collect and use your personal information under the following circumstances, and we may not respond to your requests for correction/modification, deletion, cancellation, withdrawal of consent, and information request :
Related to national security and national defense security;
Related to public security, 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 or public security agencies;
For the protection of your or other personal life, property and other major legal rights, but it is difficult to obtain your consent;
The collected information is disclosed to the public by you yourself or collected from legal and public channels (such as legal news reports, government information disclosure, etc.);
Necessary in accordance with the signing and performance of relevant agreements or other written documents with you;
We have sufficient evidence to show that you have subjective malice or abuse of rights (such as your request will endanger public safety and the legitimate rights and interests of others, or your request is beyond the scope of general technical means and commercial costs);
The collected personal information has been anonymized/de-identified;
Necessary for legitimate news reporting;
For academic research purposes, such as the need to conduct statistical or academic research for scientific research institutions;
Based on social public interests, etc.;
Circumstances stipulated by other laws and regulations.
13. How do we use cookies and similar technologies
(1) About cookies and similar technologies
A cookie is a small file containing a character string, which is sent and stored on your computer, mobile device or other device (usually encrypted) when you log in and use a website or other network content. Cookie similar technologies are other technologies that can be used for similar purposes to cookies, such as: Web Beacon, Proxy, embedded scripts, etc.
Currently, we mainly use cookies to collect your personal information. You understand and agree that with the development of technology and the further improvement of our products and services, we may also use cookies and similar technologies.
(2) How do we use cookies and similar technologies
When you use our products and/or services, we may use cookies and similar technologies to collect some of your personal information, such as: your website visiting habits, your login information, etc. Cookies and similar technologies collect such information For your use of our products and/or services, simplify your repeated steps (such as registration, login), provide you with service content that better suits your personal needs, protect your information and account security, and improve our products and services etc. We promise to use cookies and similar technologies only within the scope of the purposes described in this Privacy Policy.
If your browser allows, you can manage and (partially/fully) reject cookies and/or similar technologies through your browser settings; or delete cookies and cookies that have been stored on your computer, mobile device or other devices. /or similar technologies so that we cannot track all or part of your personal information. If you need to learn more about how to change your browser settings, please refer to the relevant settings page of your browser. You understand and are aware that some of our products/services can only be realized by using cookies or similar technologies. If you refuse to use or delete them, you may not be able to use our related products and/or services normally or fail to pass Our products and/or services have the best service experience, and may also have a certain impact on your information protection and account security.
14. How do we share, transfer and publicly disclose your personal information
(1) Sharing
For your personal information, we only collect and use it within the purpose and scope stated in this "Privacy Policy" or in accordance with the requirements of laws and regulations, and keep it strictly confidential. We attach great importance to protecting your personal information. Without your authorization, we will not share your personal information with third-party companies, organizations and individuals, unless it is anonymized or de-identified and cannot be identified or associated with you. information, and the sharing third party cannot re-identify the natural person subject of such information.
We will only share your personal information for legal, legitimate, necessary, specific, and explicit purposes, and will only share necessary personal information. If we share your sensitive personal information, we will ask for your authorization again. If a third party changes or uses your personal information beyond the scope of your original authorization and consent, we will require the third party to obtain your authorization and consent again. At the same time, we will conduct a personal information security impact assessment on the sharing and transfer of personal information in advance, and take effective technical protection measures for the output form, circulation, and use. At the level of cooperation agreements, the information protection obligations and responsibilities of partners are strictly required, and a data security protection agreement is signed with business partners before cooperation.
15. 1. Sharing necessary to realize our services/functions:
In some cases, in order to provide you with our services or realize the business functions of our products and/or services, we must share your personal information in order to realize the core functions of our products and/or services or provide the services you need services such as:
(1) Service providers that provide functional support for our products and/or services: including: providing payment related information for your order to payment institutions that provide payment services, and providing your real-name authentication information to certification institutions that provide certification services. information, provide your delivery-related information to third-party logistics companies, etc.;
(2) Third-party merchants on our platform: In order to meet your needs for purchasing products or services (including enjoying after-sales service), we will share your order and transaction-related information with third-party merchants on our platform;
(3) When we accept due diligence or audit, we will share your relevant information with external supervision and professional consulting agencies (such as auditing agencies).
16. 2. Necessary sharing within Sailing Spark:
For example: in order to provide you with consistent services based on Sailing Spark's unified account system and to facilitate your unified management, personalized recommendations, system and account security protection, etc., your personal information: account-related information (mobile phone number) may be Necessary sharing within Sailing Spark; in order to enable you to have a consistent and personalized experience in viewing movies, advertising and other services in our products and/or services, you understand and agree that Sailing Spark registration account information, device information, Information that reflects your usage habits and hobbies, such as the application information installed on the device, may be shared with our affiliated companies.
17. 3. Necessary sharing with some business partners:
You understand and agree that for the smooth development of necessary/reasonable business, meeting your requirements, fulfilling our obligations in relevant user agreements or this privacy policy, exercising our rights or complying with legal regulations, we may need to submit to some Business partners share some of your information. Our business partners include:
(1) Service provider
Provide product analysis services: In order to analyze the performance of our products and/or services and improve your experience on our platform, we may share statistical data on your product usage (such as crashes and flashbacks) with third parties. Please be aware that it is difficult to identify your personal identity by combining your information with other information;
Other suppliers, service providers and business partners: such as hardware manufacturers, telecom operators, customer support service providers, product analysis providers, etc. These supports include providing communications, security, infrastructure and IT services entrusted by us, providing Customer service, analyzing and improving data, processing and administering consumer surveys, etc.
(2) Third-party SDK service providers
Our products may contain third-party SDKs or other similar applications. If you use such services provided by third parties on our platform, you agree that they will directly collect and process your information (such as embedding code, Plug-ins, etc.), for example: if you watch a video provided by the Fengxing Mini Program SDK, you will use Fengxing’s video service. The collection and processing of information by the aforementioned service providers comply with their own privacy clauses, which do not apply to this policy. However, we will also work hard to review the third party's business access qualifications and strive to require the legal compliance and security of such service providers. In order to protect your legitimate rights and interests, if you find that these SDKs or other similar applications are at risk, you are advised to immediately terminate the relevant operations and contact us in time. The following table shows the SDKs with personal information collection functions and the rules for the collection and use of SDKs that we know:
 
- GameAnalytics:
   - Email: privacy@gameanalytics.com
   - Privacy Policy: https://gameanalytics.com/privacy/#6-changing-or-deleting-your-information
- Facebook Analytics:
   - Email: None, please refer to Privacy Policy
   - Privacy Policy: https://www.facebook.com/policy.php
-Adjust:
   - Email: privacy@adjust.com
   - Privacy Policy: https://www.adjust.com/terms/privacy-policy/
- Voodoo:
   - Voodoo does not collect any personal data and only provides SDK packages to retrieve data collected by the above partners. You can still contact them to request removal of their access to the partner interface.
   - Email: dpo@voodoo.io
 
18. 4. Other situations:
(1) Sharing with third parties in order to protect you, our other users or employees, Sailing Spark or social public interests, property or safety (such as: fraud or credit risk, etc.) from damage;
(2) Shared in accordance with the relevant agreement (for example: online agreement, platform rules, etc.) or legal documents signed between you and us;
(3) It complies with the relevant agreement between you and other third parties.
(2) Transfer
Transfer refers to the process of transferring the control of personal information to another company, organization or individual. In principle, we will not transfer your personal information, except in the following cases:
requested by you;
Have obtained your explicit authorization and consent in advance;
If we undergo a merger, acquisition, reorganization, division, bankruptcy, asset transfer or similar transaction, and your personal information may be transferred as part of such transaction, we will require the new holder to continue to abide by and perform the " The entire content of the Privacy Policy (including purpose of use, rules of use, security protection measures, etc.), otherwise we will require it to obtain your express authorization and consent again;
Circumstances stipulated by other laws and regulations.
If the transfer is necessary for the above reasons, we will inform you of the purpose and type of the transferred information before the transfer (if your personal sensitive information is involved, we will also inform you of the content of the sensitive information involved), and It will be transferred after obtaining your authorization and consent, except as otherwise stipulated by laws and regulations or otherwise agreed in this policy.
(3) Public disclosure
Public disclosure is the act of releasing information to the society or unspecified groups of people. We will not disclose your personal information to the public, except for the necessary disclosure due to the need to make punishment announcements on illegal accounts, fraudulent behavior, etc., and display relevant information in a masked manner when announcing the list of winners/winners, etc., if there are reasonable reasons If public disclosure is really necessary, we will inform you of the purpose and type of the publicly disclosed information before the public disclosure (if it involves your personal sensitive information, we will also inform you of the content of the sensitive information involved), and Public disclosure will only be made after obtaining your authorization and consent, except as otherwise stipulated by laws and regulations or otherwise agreed in this policy.
For the public disclosure of your personal information, we will fully pay attention to the risks, immediately and prudently review its legitimacy, rationality, and legality after receiving the public disclosure application, and take no less measures at the time of public disclosure and after public disclosure. It is protected to the extent of the personal information security protection measures and means agreed in this "Privacy Policy".
Please be aware that even with your authorization and consent, we will only publicly disclose your personal information for legal, legitimate, necessary, specific, and clear purposes, and try to de-identify the personal information in the publicly disclosed content deal with. You understand and are aware that de-identified or anonymized information cannot point to and identify you, and is no longer your personal information, and its public disclosure does not require your authorization and consent.
exceptions
According to laws and regulations, under the following circumstances, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent:
Directly related to national security and national defense security;
Directly related to public security, 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 or public security laws and other competent authorities;
For the protection of your or other personal life, property and other major legal rights, but it is difficult to obtain your 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 in accordance with the signing and performance of relevant agreements or other written documents with you;
The collected personal information has been anonymized/de-identified;
Necessary for legitimate news reporting;
For academic research purposes, such as the need to conduct statistical or academic research for scientific research institutions;
Based on social public interests, etc.;
Circumstances stipulated by other laws and regulations.
19. Your right to control your personal information
You have control over your personal information in our products and/or services in various ways, for example: you can access, correct/modify, delete your personal information, or withdraw your previous consent to your personal information , and you can also log out of your Sailing Spark account. In order to facilitate you to exercise your above-mentioned control rights, we provide you with operation guidelines and operation settings on the relevant function pages of the product. You can operate by yourself. If you have any doubts or difficulties during the operation, you can contact us through the methods at the end of the article Let's take control and we'll take care of it for you in a timely manner.
(1) Access right
You can inquire or access your relevant personal information in our products and/or services, including:
Account information: You can log in to your personal account at any time through the relevant product page to access the personal information in your account, including: avatar, hidden mobile phone number, etc., for example: "Avatar, mobile phone number" information in the "Mobile APP The correction/modification path in " is: My-About Us-Contact customer service to modify;
Other information: If you encounter operational problems during this visit or if you need to obtain other personal information that cannot be obtained above, you can contact us through the methods provided at the end of the article, and we will provide you with a reasonable period of time after verifying your identity. Provided by you, except as otherwise provided by laws and regulations or otherwise agreed in this policy.
(2) Right to rectification/amendment
You can modify your personal information by submitting a correction/amendment application to us. We provide you with operating instructions on the relevant function pages of the product. The path is: My—About Us—Contact Customer Service;
For the difficulties you encounter in the process of exercising the above rights, or others who may not/cannot provide you with online self-correction/modification rights, your identity has been verified, and the correction does not affect the objectivity and accuracy of the information Under certain circumstances, you have the right to correct or amend wrong or incomplete information, or under certain circumstances, especially when the data is wrong, submit your correction/amendment application to us through our published feedback and error reports, etc. Ask us to correct or amend your data, except as otherwise provided by laws and regulations. However, for security and identification reasons, you may not be able to modify some of the initial registration information submitted during registration.
(3) Right to delete
Generally speaking, we will only save your personal information for the shortest time required by laws and regulations or necessary. In order to facilitate you to exercise your above deletion right, you can submit a deletion application to us through the path: My--About Us--Contact Customer Service.
Under the following circumstances, you can directly submit a request to us to delete your personal information, unless the data has been anonymized or otherwise stipulated by laws and regulations.
We collect and use your personal information in violation of laws and regulations;
We violated the agreement with you to collect and use your personal information;
Circumstances stipulated by other laws and regulations.
Regarding the processing of your personal information after you no longer use the products and/or services we provide and cancel your Sailing Spark account, and after we terminate some or all of our products and/or services, we will discuss in other dedicated chapters/sections of this article Explain in detail for you.
You understand and agree: After you delete information from our products and/or services, we may not immediately back up the corresponding deleted information in the system, but will delete the information when the backup is updated.
(4) Claim right
If you need a copy of your personal data, you can contact us through the methods provided at the end of this Privacy Policy. After verifying your identity, we will provide you with a copy of your personal information in our services (such as basic data, identity information), except as otherwise provided by laws and regulations or as otherwise agreed in this Policy.
(5) Right to withdraw consent
If you want to change the scope of authorization of related functions (for example: location, address book, camera, microphone, schedule items, message push, etc.), you can modify personal settings through your hardware device, or in our products or services. Related function setting interface for operation processing (for example: the withdrawal consent path of the "Location" function in "SparkTv APP" is: My - Privacy Settings). You can also permanently withdraw all of our authorization to continue collecting your personal information by logging out of your Sailing Spark account. If you encounter operational problems during this process, you can contact us through the methods provided at the end of this "Privacy Policy".
When you cancel the authorization to collect relevant personal information, we will no longer collect the information, and we will no longer be able to provide you with the above-mentioned corresponding services; but you understand and agree that unless you exercise the aforementioned "deletion right", your This behavior will not affect our processing and storage of personal information based on your previous authorization.
(6) Cancellation right
We provide you with Sailing Spark account cancellation authority, you can cancel your account through the cancellation function (for example: "Account Cancellation" function path: My-Account Cancellation) or through other methods we publicize (but laws and regulations stipulate otherwise or as otherwise agreed in this policy) To cancel an account, you must prove that the account belongs to you and complies with laws and regulations. Once you cancel your account, you will not be able to use the services of our full-line user products and will automatically give up your existing rights and interests, so please be careful operate. Unless otherwise stipulated by laws and regulations, after canceling the account, we will stop providing you with all our products and services, and all content, information, data, and records of our products and services that you have used through this account will be deleted. Deletion or anonymization.
(7) The right to be notified in advance of the suspension of operation of products and/or services
We are willing to accompany you all the time. If some or all of our products and/or services are forced to stop operating due to special reasons, we will send you emails or emails on the main page of the products and/or services 15 days in advance. We will notify you in other appropriate ways that can reach you, and will stop collecting your personal information. At the same time, we will delete or delete your personal information held after exceeding the necessary and minimum period stipulated by laws and regulations. Anonymization.
(8) Help Feedback
We provide you with customer service and feedback channels, for example: the operation path in "SparkTv APP" is: My-About Us-Contact Customer Service. At the same time, you can give us your feedback or suggestions via fun@sailingspark.com, or you can also mail them to us. Our receiving address is provided at the end of this article.
20. How do we store and protect your personal information
(1) Storage of personal information
Storage location: We store your personal information within the territory of the People's Republic of China in accordance with laws and regulations. At present, we do not currently have any scenarios where your personal information is stored across borders or provided overseas. If it is necessary to store or provide personal information overseas, we will separately notify you (including the purpose of export, recipient, method and scope of use, content of use, security measures, security risks, etc.) and ask you again Authorized consent, and strictly require the receiver to process your personal information in accordance with this "Privacy Policy" and other relevant requirements;
Storage period: We retain your personal information for the shortest period necessary for the purpose of providing our products and services, for example: when you use our registration and membership functions, we need to collect your mobile phone number, and in After you provide it and during your use of this function, we need to keep your mobile phone number for you in order to provide you with this function normally and protect your account and system security. After the above storage period is exceeded, we will delete or anonymize your personal information. However, unless you exercise the right to delete, cancel your account, or otherwise stipulated by laws and regulations (for example: "E-Commerce Law" stipulates: commodity and service information, transaction information shall be stored for no less than three years from the date of transaction completion).
(2) Protection of personal information
We have always attached great importance to the protection of users' personal information security. For this reason, we have adopted multi-level protection measures such as security technical measures in line with industry standards and supporting organizational structures and management systems to minimize your information from being leaked, damaged, and misunderstood. risks of use, unauthorized access, unauthorized disclosure and alteration. include:
21. Data security technical measures
(1) In terms of secure data transmission, cryptographic technologies such as transport layer security protocols are used to prevent the risk of sniffing, eavesdropping and interception of the transmission link through Https and other methods, and establish a safe and private data collection environment to ensure the privacy and integrity of data collection ;
(2) In terms of data security storage, classify and classify data and take additional security protection measures such as independent and encrypted storage for users' personal sensitive information;
(3) In terms of security control of data access and use, implement strict data authority control mechanisms, adopt multiple identity authentication technologies, and monitor behaviors that can process your information to prevent data from being accessed in violation of regulations and used without authorization;
(4) Establish a complete audit mechanism to monitor and audit the entire process of the data life cycle to prevent your personal information from unauthorized access, public disclosure, use, modification, man-made or accidental damage or loss;
(5) Other measures to achieve data security protection.
22. Data security organization and management measures
(1) Establish a dedicated personal information protection department, establish relevant internal control management processes, and adopt the principle of minimizing authority for staff who may have access to your information;
(2) Establish management systems such as data classification and grading systems, business data security use specifications, and data cooperation specifications to ensure that the disposal of your information in the collection, transmission, use, storage, transfer, and destruction meets relevant laws and regulations and security requirements ;
(3) Regularly organize employees to participate in training related to security and privacy protection and require them to complete the prescribed assessments to strengthen employees' awareness of the importance of protecting personal information;
(4) Passed the third-level certification of information security level protection by the Ministry of Public Security, and established a good coordination and linkage mechanism with regulatory agencies and third-party evaluation agencies to resist and deal with various information security threats in a timely manner, providing comprehensive protection for your information security ;
(5) Other feasible safety organization and management measures.
23. Guarantee on terms of cooperation agreement
(1) Before we indirectly collect your personal information from a third party, we will clearly require the third party to collect and process it (such as sharing, etc.) personal information after obtaining your express consent in written form (such as a cooperation agreement, letter of commitment) Information, at the level of written agreement, the third party is required to make a commitment to the legality and compliance of the source of personal information. If the third party violates the law, we will clearly require the other party to bear the corresponding legal responsibility;
(2) Before we share your personal information with our business partners, we will strictly require the information protection obligations and responsibilities of our partners. In the cooperation agreement, we strictly stipulate the terms of the business partners' user information confidentiality obligations. Once there is any violation , will bear the corresponding legal responsibility;
(3) Contents clearly agreed in other cooperation agreements.
24. Handling of security incidents
(1) We have established a reasonable, effective, scientific and sound security emergency response system, formulated a number of security management systems, clarified the classification and grading standards of network security incidents, security emergency response organizations and responsibilities, and based on different types of security incidents and an appropriate emergency response plan has been formulated at the level, and the reporting process and emergency response process for security incidents (including research and judgment, analysis, suppression, eradication, recovery, release of results, and experience summary) have been clearly regulated. At the same time, we also have a Sailing Spark security emergency response center, which is maintained by a professional security technology and operation team, which facilitates timely and effective response and handling of various security vulnerabilities and emergencies, and cooperates with relevant departments to trace and combat security incidents;
(2) In the unfortunate event of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and you can prevent and reduce the incident on your own. Risk advice, remedies for you, etc. We will promptly inform you of the relevant circumstances of the incident by email, letter, phone call, push notification, etc. When it is difficult to inform the personal information subject one by one, we will issue an announcement in a reasonable and effective manner. At the same time, we will also actively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities;
(3) Please know and understand that the Internet is not an absolutely safe environment, and we strongly recommend that you assist us in ensuring the security of your account through safe methods and complex passwords. If you find that your personal information is leaked, especially your account or password, please contact us immediately according to the contact information provided at the end of this privacy policy, so that we can take corresponding measures to protect your information security.
25. Protection of Minors
Most of Sailing Spark's products and/or services are mainly provided for adults. For these products and/or services, we will not take the initiative to directly collect personal information from minors. If minors need to use them, they should first Obtain the consent of their guardians (including this policy), use and submit personal information after the consent and guidance of the guardians; we hope that guardians can also actively educate and guide minors to enhance their awareness and ability to protect personal information and protect minors Personal information security. We will strictly fulfill the obligations and responsibilities for the protection of minors stipulated by the law. We will only collect, use, share, transfer or disclose the personal information of minors when the law permits, the guardian agrees or is necessary to protect the minors. If If we find that minors have used our products and/or services without prior consent from their guardians, we will do our best to contact the guardians and delete the relevant personal information of the minors as soon as possible at the request of the guardians.
26. Updates to this "Privacy Policy"
We encourage you to review our Privacy Policy each time you use our products or services. In order to provide you with better services, we may update the terms of this "Privacy Policy" at any time, and such updates constitute a part of this "Privacy Policy". If such updates result in a substantial reduction or major change of your rights under this Privacy Policy, we will notify you by prompting or sending you emails, push messages or other means before this policy takes effect , so that you can review the revised Privacy Policy in time before you choose to continue using our products and/or services. Therefore, in order for you to receive notifications in a timely manner, it is recommended that you notify us in time when your contact information is updated. In the case of policy updates, if you continue to use our services, it means that you have fully read, understood and agreed to be bound by the revised Privacy Policy. If you continue to use our services after the update of this policy takes effect, it means that you have fully read, understood and accepted the updated text and are willing to be bound by the updated text.
The above-mentioned "major changes" include but are not limited to:
Significant changes to our service model. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;
We have undergone major changes in terms of ownership structure, organizational structure, etc. Such as all changes caused by business adjustments, bankruptcy mergers and acquisitions, etc.;
The main object of personal information sharing, transfer or public disclosure changes;
Significant changes to your rights to participate in the processing of personal information and how to exercise them;
When there are changes in the responsible department, contact information and complaint channels that we are responsible for handling personal information security;
When the personal information security impact assessment report indicates that there is a high risk;
When other important situations or situations that may seriously affect your personal rights and interests occur.
27. How to contact us
(1) If you have any complaints, suggestions, or questions about the implementation of this policy or our privacy protection-related matters, you can contact us in the following ways, and we will reply to you within 15 working days after verifying your user identity :
28. Special email channel: In order to better protect your rights and interests, we have specially set up an email address of xuande@sailingspark.com, through which you can contact us;
29. Personal Information Protection Commissioner: You can send an email to xuande@sailingspark.com;
(2) We will reply to you as soon as possible within 15 days after receiving your comments and suggestions and verifying your user identity. Generally, we will not charge you a service fee for this. However, you understand and know that we will not be able to respond to your request under the following circumstances:
Related to national security and national defense security;
Related to public security, public health, and major public interests;
Related to criminal investigation, prosecution and trial;
There is sufficient evidence 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.
(3) If you are dissatisfied with our reply, or our handling of your personal information violates your legitimate rights and interests, and we still refuse to improve after you give us feedback, you can report to the industry and commerce, public security and other regulatory authorities to make complaints and reports..