PRIVACY POLICY


We may collect and use relative information about you and your end customers in connection with using or accepting the Value-added Telecom Services about   Netskyper. We are committed to strictly protecting the privacy of you and your end customers. This policy is intended to show you and your end customers how we collect and use the foregoing information.

This policy is closely related to the use of our value-added telecom software or the acceptance of our value-added telecom services by you and your end customers. We hope that you and your end customers will read the policy carefully. This Policy will be amended from time to time and we will notify you of such changes via web posting, e-mail, etc. You and your end customers are requested to give the necessary attention to ensure that the latest version of this policy is always understood.

By using or continuing to use our services, you and your end customers agree that we collect and use information about you and your end customers in accordance with this policy.

1. The information we might collect

When we provide our services, we may collect, store and use the following information that is relevant to you and your end customers. If you and your end customers do not provide relevant information, you may not be able to connect to become a user of us or to be provided with some of our services. It may also appear that the relevant services can’t be intended to achieve.

1.1 Information provided by you and your end customers

1.1.1 Relevant personal information provided to us by you and your end customers when using our services, such as telephone number, e-mail, etc.

1.1.2 Shared information that you and your end customers provide to other parties through our services, and information that you and your end customers store when using our services.

1.2 Information shared by others about you and your end customers

Shared information about you and your end customers provided by other parties when using our services.

 

1.3 Information we obtain about you and your end customers

When you and your end customers use the service, we may collect the following information:

1.3.1 Log information which refers to the what may be automatically collected by the system when you and your end customers use our services, including:

Device or software information, such as configuration information provided by you and your end customers' mobile devices, web browsers or other programs used to connect to our services, you and your end customers' IP addresses and version and device identification numbers used on mobile devices;

Information about mobile applications (App) and other software that you and your end customers have used, and information about mobile applications and software that you and your end customers have used;

Information that you and your end customers communicate through our services;

The information (metadata) contained in the content that you and your end customers share through our services.

2. The way we might collect information

2.1 We or our third party partners may use various ways to collect and use information about you and your end customers, record you and your end customers’ behaviors related to value-added telecom, and store such information as log information.

2.2 We may collect information about you and your end customers with the intention of providing you and your end customers with a more personalized user experience and services for the following purposes:

2.2.1 Record the identity of you and your end customer;

2.2.2 Analyze the service condition used by you and your end customers;

2.3 While we collect information about you and your end customers for the above purposes, we may provide the non-personally identifiable information collected to other partners after statistical processing for the purpose of analyzing how users use our services. But such behaviour will not be used for advertising services.

3. How we might use information

3.1 The information we may collect in the course of providing services to you and your end customers may be used for the following purposes:

3.1.1 Provide services to you and your end customers;

3.1.2 Use our services for the purpose of authentication, customer service, security prevention, fraud monitoring, archiving and backup to ensure the safety level of the products and services we provide to you and your end customers;

3.1.3 Help us design new services and improve our existing services;

3.1.4 Make us know more about how you and your end customers access and use our services, and help us pay more attention on responding to you and your end customers’ personalized requirements, such as language settings, position settings, personalized services and instructions, or other potential aspects of the response for you, your end users and other users;

3.1.5 Provide services or supports that are more relevant to you and your end customers;

3.1.6 Evaluate the cost-effectiveness ratio of our services and the effect of sales promotion and promotional activities for other customers, and therefore make improvement;

3.1.7 Be used for software certification or software upgrade management;

3.1.8 Involve you and your end customers in surveys about our products and services.

3.2 In order to provide a better experience for you and your end customers and improve our services or be used by other purposes agreed by you and your end customers, subject to the relevant laws and regulations, we may use the information collected through one of our services in a pooled or personalized manner for our other services. For example, the information collected when you and your end customers are using one of our normal services may be used in another service to provide specific content to you and your end customers, or to show you and your end customers information that is relevant to you and your end customers but not universally exposed to you and your end customers.If we provide an option in the relevant service, you and your end customers may also authorize us to use the information provided and stored in the service for our other services.

4. The information we might share

We and our affiliates will by no means share you and your end customers’ personal information with any third party without you and your end customers' consent, except as follows:

4.1 we and our affiliates may share the personal information of you and your end customers with our affiliates, partners, and third party suppliers, contractors and agents (such as the communication service providers who send out e-mails and notices on behalf of us, or  map service providers who offer us the data of your position) (they may not be regulated by the scope of law where you and your end customers are), used for the following purposes:

4.1.1 Provide our services to you and your end customers;

4.1.2 Achieve the purpose described in the section 'How we use information';

4.1.3 Perform our obligations in the Service Framework Contract, Export Transmission Contract or the obligations in this Privacy Policy and exercise our rights;

4.1.4 Understand, maintain and improve our services.

4.2 If we or our affiliates share you and your end customers’ personal information with any of these third parties described above, we will endeavor to ensure that such third parties comply with this Privacy Policy and other appropriate measures of confidentiality and security that we require them to comply with when using you and your end customers’ personal information.

4.3 With the continued development of our business, we and our affiliates may engage in mergers, acquisitions, asset transfers or similar transactions. Under such circumstances, you and your end customers' personal information may be transferred as part of such transactions. We will in time notify you and your end customers before such transfer.

4.4 We or our affiliates may also retain, save or disclose personal information about you and your end customers for the following purposes:

4.4.1 Comply with applicable laws and regulations;

4.4.2 Comply with court orders or other legal procedures;

4.4.3 Comply with the requirements of relevant government agencies;

4.4.4 Use in reasonable and necessary ways in order to comply with applicable laws and regulations, safeguard the public interest, or protect the personal and property safety or legitimate rights and interests of us, our customers, other users or employees;

4.4.5 Other necessary circumstances.

5. You and your end customers' rights to personal information

We will do everything possible to take appropriately technical measures to ensure that you and your end customers can access, update and correct their own information in connection or other personal information provided when using our services. When accessing, updating, correcting and deleting the above information, we may require you and your end customers to authenticate your identification in order to ensure the account security.

Based on the relevant provisions of the GDPR of the EU, if you and your end customers are users of the European Economic Area (EEA), you and your end customers shall have the right to access, correct, delete, restrict, transfer and object to the personal information provided to us.

5.1 Right of access

You and your end customers have the access to personal information, the right to inquire about its origin, storage, retention time, and the right to copy personal information. If you and your end customer's requests for personal information exceed reasonable limits, or may interfere with the legitimate rights and interests of other users, we have the right to charge you and your end customers a certain amount of fees or refuse you and your end customer's certain requests.

5.2 Right of correction

We will strive to ensure that you and your end customers' personal information is complete and accurate. If you and your end customers believe that the information is inaccurate or needs to be updated, you may modify it by yourself or notify us to modify it. We have no obligation to verify the authenticity of information submitted by you or your end customer.

5.3 Right of deletion

We will endeavour to ensure that only the information necessary to offer the related service is collected. If you and your end customers find that you and your end customers’ information is no longer necessary for the provision of our services, that the information is collected by us without our permission, or that other reasonable reasons have been found, you and your end customers may delete the information by yourself or notify us to delete it. Some of these information may cause us to be unable to provide you and your end customers with normal and complete services. The right of deletion of you and your end customers may be restricted by freedom of expression, freedom of communication, third party interests, public interests, legal compulsion, etc.

5.4 Right of restriction

In order to make efficient use of server resources, we have the right to decide to clean up user information irregularly. If you and your end customers believe that the information we have previously collected is illegal or infringing, or you and your end customers have found other reasonable reasons, you and your end customers may notify us to suspend the liquidation of 's information.

5.5 Right of transfer

You and your end customers have the right to transfer your personal information to a third party other than us, and you and your end customers may contact us to assist with the information transfer. If direct transfer of information is not possible with existing technology, we will provide information directly to you and your end customers.

5.6 Right of objection

You and your end customers have the right to notify us to stop the collection and analysis of personal information towards you and your end customers. The information collected for the purpose of direct marketing will be unconditionally banned to be used within a reasonable period of time upon receipt of notification from you and your end customers.

6. Information security

6.1 We may retain personal information about you and your end customers only for such period as is necessary for the purposes set forth in this Privacy Policy or for such period required by laws and regulations.

6.2 We may use various security technologies and procedures to prevent the loss, improper use, unauthorized access or disclosure of information. For example, in some services, we will use encryption technologies, such as Security Socket Layer(SSL), to protect the personal information provided by you and your end customers. But please do understand, the  information of you and your end customers, because of the limitations of technology and the various malicious means that may exist in the internet industry, may not be completely secure even with all efforts to strengthen security measures. You and your end customers need to understand that the systems and communication networks that you and your end customers use to access our services may have problems due to factors beyond our control.

7. E-mails and messages that we might send to you and your end customers

7.1 Customized e-mails and information sending

When you and your end customers use our services, we may use your information to send e-mails, news or push notifications to you and your end customers’ devices. If you and your end customer do not wish to receive this information, you may choose to unsubscribe it on the device according to our relevant tips.

7.2 Notices related to our services

We may issue service-related notices to you and your end customers if necessary, such circumstance may occur when a service is suspended for system maintenance. You and your end customers may not be able to cancel these notices relating to the service that are not for promotion.

8. Scope of application of our Privacy Policy

8.1 This policy applies to all of our services except certain specific services. Such services will be subject to specific privacy policies. Specific privacy policies for certain services will put emphasis on how we use you and your end customers’ information in such services. The privacy policy for this particular service is certainly part of this Privacy Policy. If there is any inconsistency between the specific privacy policy and this Privacy Policy, the specific privacy policy shall prevail.

8.2 Except as otherwise provided in this Privacy Policy, the terms used in this policy will have the same meaning as those defined in the Value-added Telecom Licensing and Service Agreement. Anything not covered in this policy shall be carried out in accordance with the Value-added Telecom Licensing and Service Agreement.

8.3 Please do notice that this Privacy Policy does not apply to you and your end customers as follows:

8.3.1 Information collected by third party services (including any third party websites) accessed through our services;

8.3.2 Information collected through other companies or agencies that advertise in our services.

9. Exceptions to our Privacy Policy

9.1 Our services may include or link to social media or other services (including websites) provided by third parties, such as:

9.1.1 You and your end customers may use the 'share' button to share certain contents to our services, or you and your end customers may use the third party connection service to log in to our services. These functions may collect information about you and your end customers (including you and your end customers’ log information) in order to enable the operation of above functions;

9.1.2 We may provide links to you and your end customers through advertising or other means of our services, so that you and your end customers may have access to third party services or websites.

9.2 Such third party social media or other services may be operated by the relevant third party or by us. You and your end customers’ use of such third party social media services or other services (including any personal information provided by you and your end customers to such third parties) is subject to such third party's terms of service and their privacy policy but not to this policy, which you and your end customers need to read carefully. This policy applies only to the information we collect and does not apply to the services provided by any third parties or the rules governing the use of third party information, and we are not responsible for the use of information provided by you and your end customers by any third party.

10. Application and jurisdiction of law

10.1 This Privacy Policy shall be governed by the laws of the People's Republic of China. If the laws and regulations of the place where our officially recognized services are accepted have other provisions over jurisdiction, they shall be implemented by reference.

10.2 Any disputes or controversies arising out of this Privacy Policy shall first be settled through friendly consultation. If no agreement can be reached through negotiation, either party may file a lawsuit with the People's Court of Pudong New District, Shanghai.

10.3 Both Chinese and English versions of this Privacy Policy are provided. In case of any inconsistency, the Chinese version shall prevail.

11. Contact us

You and your end customers can contact our Privacy Policy Officer by the following way:

Kuijun Chen

137 5136 3393

chenkuijun@wsdashi.com