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Who We Are

Our website address is: https://commaker.com.

What is the privacy policy for ComMarker B series and ComMarker T+M software

1. Introduction

"ComMarker" is a service product provided  (hereinafter referred to as "we"). We attach great importance to the privacy of users and the protection of personal information. We will take corresponding security protection measures in accordance with the relevant requirements of the "Network Security Law" and other national laws and regulations, and try our best to keep your personal information safe and controllable. When you use this product, we may collect and use your relevant information. This privacy policy will explain to you how we collect, use, store, share and transfer this information when you use this product, and how we provide you with access, update, delete and protect this information:

1) Clear and easy to understand

 We will try our best to explain the privacy policy to you in plain language, so that you can have a clearer understanding of how we protect and process your information we collect.

2) Protection of rights and interests

We will take sufficient and reasonable measures to protect your privacy rights.

3) Respect users

We respect the free exercise of users' right to choose, right to know and other rights, and allow you to manage your personal information.

4) Necessary security

We will only collect necessary information and use this information to provide you with safe and detailed services.

5) Timely and considerate

We will always listen to your inquiries and answer your questions as soon as possible.

We hope you read the "Privacy Policy" (hereinafter referred to as "this Policy") carefully to learn more about how we collect and use information, so that you can better understand our services and be more in line with whether to choose services and which services to choose. Express what you really mean.

Please read this policy carefully before registering or using our services. If you use our services, you agree to what we have stated in this policy.

If you have questions, please contact us.

For better explanation, the following concepts in this policy refer to:

Frequently used personal device information: refers to the information describing the basic situation of personal frequently used devices, including hardware serial number, device MAC address, software list, unique device identification code (such as IMEI/IDFA/OPENUDID/GUID, SIM card IMSI information, etc.) .

Personal GPS location information: refers to including whereabouts track, precise positioning information, accommodation information, latitude and longitude, etc.

2. How we collect and use your personal information？

Personal information refers to various information recorded electronically or in other ways that can identify a specific natural person or reflect the activities of a specific natural person alone or in combination with other information. We will collect and use your personal information for the following purposes described in this policy. Personal information:

Business functions that collect personal information and personal information collected

We will provide you with the following services and collect the information listed below when providing the following services:

1) Business function: user registration. When you register for the ComMarker service, in order to complete the account creation, you need to provide the following information for us to collect: mobile phone permissions, mobile phone number or WeChat authorization, nickname, birthday, preferred gender, personal photos, and this information is collected to help you complete the ComMarker registration , get a ComMarker account, and use this to protect the security of your ComMarker account.

In order to ensure platform security and operational security, we will apply for system permissions to collect device information such as mobile phone numbers, IMEI, IMSI, and local application installation lists for platform security risk control.

Mobile phone numbers and personal photos are sensitive information, and such information is collected to meet the requirements of the Internet real-name system in national laws and regulations and to complete the registration of the ComMarker account.

The above information you provide will continue to authorize us to use it during your use of the service. We will keep your information until you cancel your account. When you cancel your account, we will stop using and delete the above information.

The above information is only stored within the territory of the People's Republic of China. If cross-border transmission is required, we will separately obtain your authorization and consent.

2) Business function: shield mobile phone contacts. When you use the service of blocking mobile phone contacts, in order to better protect your personal privacy, you need to provide the following information for us to collect: Contacts permission.

The address book permissions are sensitive information. If you provide the above information, you may not be matched with users in your mobile phone address book when using ComMarker's services.

 If you do not provide such information, you may not be able to use the service of blocking mobile phone contacts normally.

The above information you provide will continue to authorize us to use it during your use of the service. We will keep your information until you cancel your account. When you cancel your account, we will stop using and delete the above information.

The above information is only stored within the territory of the People's Republic of China. If cross-border transmission is required, we will separately obtain your authorization and consent.

3) During use, if you provide the following additional information, it will help us provide you with better service and experience: Personal GPS location information. However, if you do not provide this information, it will not affect the basic business functions of using this service.

Personal GPS location information is sensitive information.

The above information you provide will continue to authorize us to use it during your use of the service. We will keep your information until you cancel your account. When you cancel your account, we will stop using it and delete the above information.

The above information is only stored within the territory of the People's Republic of China. If the cross-border transmission is required, we will separately obtain your authorization and consent.

3.  How do we use cookies, similar technologies and SDK technologies？

cookies

In order to ensure the normal operation of the website and provide you with an easier access experience, we may store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names and some numbers and characters. You can perform corresponding data clearing operations in your browser.

other technologies

In addition to cookies, we also use other similar technologies on our website. The member SMS notification or the notification on the ComMarker assistant site that we send to you may contain an address link to the content of our website. If you click on the link, we will track this click to help us understand your product or service preferences so as to facilitate We proactively improve the customer service experience. If you do not want your activities to be tracked down in this way, you can unsubscribe from our mail list at any time.

4. How do we share, transfer and publicly disclose your personal information？

shared

We will not share your personal information with companies, organizations and individuals other than ComMarker service providers, except in the following cases:

1) Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties;

2) Sharing under statutory circumstances: We may share your personal information externally in accordance with the provisions of laws and regulations, the needs of litigation dispute resolution, or the legal requirements of administrative and judicial authorities;

3) Sharing with affiliated companies: Your personal information may be shared with our affiliated companies in order to facilitate us to jointly provide services to you based on associated accounts, and to protect the personal and property safety of ComMarker affiliated companies or other users or the public from infringement. We will only share necessary personal information (for example, we will share your necessary account information with affiliated companies to facilitate your use of our affiliated company’s products or services through your ComMarker account), if we share your personal sensitive information or affiliated companies change personal information The use and processing purpose of the information will ask for your authorization and consent again;

4) Sharing with authorized partners: only to achieve the purpose stated in this privacy policy, some of our services will be jointly provided by us and authorized partners. We may share some of your personal information with our partners to provide better customer service and user experience. For example, arranging for partners to provide services. We will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share personal information necessary to provide services. Our partners have no right to use the shared personal information for other purposes unrelated to products or services.

We send information to suppliers, service providers and other partners who support our business, including providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertisements and services, providing customer service, payment facilitation Or conduct academic research and surveys.

We will sign strict data protection agreements with companies, organizations and individuals with whom we share personal information, requiring them to process personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

 

Transfer

We will not transfer your personal information to any company, organization or individual, except in the following cases:

1) Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

2) In cases involving mergers, acquisitions or bankruptcy liquidation, or other situations involving mergers, acquisitions or bankruptcy liquidation, if the transfer of personal information is involved, we will require new companies and organizations that hold your personal information to continue to be bound by this policy. Otherwise, we will require the company, organization and individual to seek your authorization and consent again.

 

Public disclosure

We will only publicly disclose your personal information under the following circumstances:

  1. With your explicit consent or based on your active choice, we may publicly disclose your personal information;
  2. If we determine that you have violated laws and regulations or seriously violated ComMarker’s relevant agreement rules, or to protect the personal and property safety of ComMarker and its affiliated company users or the public from infringement, we may levy according to laws and regulations or ComMarker’s relevant agreement rules. Disclose personal information about you with your consent, including relevant violations and the measures ComMarker has taken against you.

Exceptions to obtaining prior authorization and consent when sharing, transferring, and publicly disclosing personal information

In the following situations, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent:

1) Related to national security and national defense security;

2) Related to public security, public health, or major public interests;

3) Related to criminal investigation, prosecution, trial and execution of judgments;

4) For the protection of your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain the consent of the person;

5) Personal information that you disclose to the public by yourself;

6) Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels.

According to the law, sharing and transferring personal information that has been de-identified and ensuring that the data recipient cannot restore and re-identify the subject of personal information is not an act of external sharing, transfer and public disclosure of personal information. Storage and processing will not require further notice to you and your consent.

5. How do we protect your personal information？

In order to protect your information security, we will strictly abide by the technical measures and operating procedures required by laws and regulations and other normative documents to protect your information confidentiality, and at the same time:

1) We have taken reasonable and feasible security protection measures in line with common industry solutions to protect the security of the personal information you provide, and prevent personal information from unauthorized access, public disclosure, use, modification, damage or loss. We will use encryption technology to improve the security of personal information; we will use trusted protection mechanisms to prevent malicious attacks on personal information; we will establish a strict internal control system, establish a sound and adequate management process, and we will deploy access control mechanisms , try our best to ensure that only authorized personnel can access personal information; and we will hold security and privacy protection training courses to strengthen employees' awareness of the importance of protecting personal information.

2) We have an industry-leading data security management system centered on data and centered around the data life cycle, which improves the security of the entire system from multiple dimensions, such as organizational construction, system design, personnel management, and product technology.

3) We will take reasonable and feasible measures to avoid collecting irrelevant personal information. We will only retain your personal information for the period necessary to achieve the purposes stated in this policy, unless an extended retention period is required or permitted by law.

4) The Internet is not an absolutely safe environment, we strongly recommend that you do not use non-ComMarker communication methods to send personal information. You can connect and share with each other through our services. When you create a communication, transaction or sharing through our services, you can independently choose the object of communication, transaction or sharing, as a third party who can see your transaction content, contact information, communication information or sharing content and other related information.

If you find that your personal information, especially your account or password, has been leaked, please contact ComMarker customer service immediately so that we can take corresponding measures according to your application.

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 secure.

We will update and disclose the content of reports such as security risks and personal information security impact assessments in accordance with the requirements of laws and regulations.

The Internet environment is not 100% secure, and we will do our best to ensure or guarantee the security of any information you send us. If our physical, technical or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering or destruction of information, resulting in damage to your legitimate rights and interests, we will bear corresponding legal responsibilities.

After an unfortunate personal information security incident occurs, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and the information that you can independently prevent and reduce risks. Suggestions, remedies for you, etc. We will promptly inform you of the event-related situation through push notifications, and send announcements 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.

6. How do you manage your personal information/your rights

Personal Information Inquiry

You have the right to access your personal information, except for exceptions provided by laws and regulations.

If you are unable to access such personal information, you can contact us through ComMarker customer service at any time. We will respond to your access request within 15 days.

For other personal information generated during your use of our products or services, we will provide you with relevant arrangements.

Correction of personal information

When you find that the personal information we process about you is wrong, you have the right to ask us to make corrections or additions.

Personal Information Deletion

You can delete some of your personal information through the methods listed in this article.

You can request us to delete your personal information under the following circumstances:

1) If our handling of personal information violates laws and regulations;

2) If we collect and use your personal information without your explicit consent;

3) If our handling of personal information seriously violates the agreement with you;

4) If you no longer use our products or services, or you voluntarily cancel your account;

5) If we no longer provide you with products or services permanently.

If we decide to respond to your deletion request, we will also notify the subjects who obtained your personal information from us as much as possible and request them to delete them in a timely manner, unless laws and regulations provide otherwise, or these subjects have obtained your independent authorization.

When you delete information from our service, we may not delete the corresponding information from the backup system immediately, but we will delete the information when the backup is updated.

User account logout

After you voluntarily cancel your account, we will stop providing you with products or services, and delete or anonymize your personal information in accordance with the requirements of corresponding laws.

Withdraw consent granted

Every business function requires some basic personal information to be completed. In addition, for the collection and use of additional personal information, you can give or withdraw your authorization by yourself or by contacting ComMarker customer service.

When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous processing of personal information based on your authorization.

In some business functions, we may only make decisions based on non-human automatic decision-making mechanisms including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will also provide appeal methods on the premise of not infringing on ComMarker's trade secrets or other user rights and social public interests.

In response to your above request

For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

We will reply within 15 days. If you are not satisfied with our answer, you can also file a complaint through ComMarker customer service.

For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost depending on the situation. We may deny requests that are unreasonably repetitive, require excessive technical means (for example, require the development of new systems or fundamentally change existing practices), pose a risk to the legitimate rights and interests of others, or are highly impractical.

 

Related restrictions

In the following situations, we will not be able to respond to your request in accordance with the requirements of laws and regulations:

  1. Related to national security and national defense security;
  2. Related to public security, public health, or major public interests;
  3. Related to criminal investigation, prosecution, trial and execution of judgments;
  4. There is sufficient evidence that the personal information subject has subjective malice or abuse of rights;
  5. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
  6. Those involving commercial secrets.

7. How do we handle personal information of minors

This software prohibits minors from registering and using it. If we find that we have collected personal information of minors, we will try to delete the relevant data as soon as possible.

8. Location and period of storing information, how your personal information is transferred globally

The region where personal information is stored

In strict accordance with the provisions of laws and regulations, we store the personal information of users collected and generated in China in China.

Transfer of personal information abroad

The personal information we collect and generate during our operations in the People's Republic of China is stored in China. If personal information is exported abroad in the future, we will strictly abide by the relevant provisions of the laws and regulations of the People's Republic of China, and at the same time evaluate the information security of the exported information and obtain your explicit authorization, but you will publish news, etc. across the border through the Internet. Personal initiative is excluded.

In view of the above situations, we will ensure that your personal information is adequately protected in accordance with this Privacy Policy.

DURATION OF STORED INFORMATION

Generally speaking, we only retain your personal information for the shortest period necessary to achieve the purpose, and the personal information beyond the corresponding period will be deleted or anonymized for processing. However, in the following cases, we may change the storage period of personal information to comply with legal requirements:

  1. To comply with the relevant provisions of applicable laws, regulations or policies and other normative documents;
  2. In order to comply with the decisions of administrative agencies or similar authorized organizations, the judgments and rulings of judicial agencies, the rulings of arbitration agencies, or other legal procedures;
  3. We have reasons to believe that we need to abide by relevant laws and regulations;
  4. Reasonable and necessary purposes to implement relevant service agreements or this policy, safeguard social and public interests, and protect the personal and property safety or other legal rights of our customers, us or our affiliates, other users or employees, and other third parties.

When ComMarker ceases to operate, we will notify you by means of push notifications, website or in-app announcements, and delete or anonymize your personal information within a reasonable period of time.

9. How to update this privacy policy

Our Privacy Policy is subject to change. In the event of changes in business functions, purposes of use, or changes in the contact information of the person in charge of personal information protection, we will revise the Privacy Policy accordingly.

We will not limit your rights under this Privacy Policy without your express consent. For major changes, we will provide prominent notices (including the way we will publicize them through ComMarker). You may also review this Privacy Policy periodically for the latest terms.

Major changes referred to in this policy include, but are not limited to:

  1. Major changes have taken place in our service model. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;
  2. The main object of personal information sharing, transfer or public disclosure changes;
  3. There are major changes in your right to participate in the processing of personal information and how to exercise it;
  4. When our responsible department, contact information and complaint channels for handling personal information security change;
  5. When the personal information security impact assessment report indicates that there is a high risk.

If you choose to continue to use our services after receiving the notice, you agree to be bound by the revised policy.

We will also archive the old version of this policy for your review, and you can apply to us for review through the aforementioned contact information.

10. How to Contact Us/User Complaint Channel and Feedback Mechanism

If you have questions or suggestions about this policy or related matters, we have established a dedicated department for personal information protection, and you can contact us through the following complaint channels. We will properly accept and give timely feedback on your appeal, and reply within fifteen days after verifying your user identity.

 

If you are not satisfied with our response, especially if you believe that our personal information processing behavior has damaged your legal rights, you can also seek a solution by filing a lawsuit with the court with jurisdiction in the place where the defendant is domiciled.

11. Scope of application

All services provided by ComMarker use this Privacy Policy. However, please note that this Privacy Policy does not apply to services provided by other companies or individuals, and the services are governed by the privacy policies of other companies or individuals.