SmartKey Privacy Policy
Release date: October [2023]
Effective time: October [2023]
Update date:October [2023]
Introduction
Welcome to download intelligent keys and use the products and services provided by intelligent keys.
We values the trust you have placed in us when providing your personal information to us. We will process your personal information in accordance with this Privacy Policy and protect the security of your information.
Intelligent Key strictly abide by laws and regulations, is committed to improving the transparency of information processing, and has formulated this Privacy Policy to enhance your convenience of information management and protect your information and privacy security.
We hope that you will carefully read the Privacy Policy (hereinafter referred to as the "Policy") and understand in detail how we collect and use information, so that you can better understand our services and make appropriate choices.
If you use the services of SmartKey, it means that you have fully understood and agreed with the content stated in this policy.
Through this policy, we hope to help you understand the following:
I. How do we collect your Personal information
Ii. Purposes for which we collect and use your personal information
Iii. How do we use your personal information
How do we use cookies and similar technologies
V. How do we share, transfer, entrust and publicly disclose your personal information
Vi. How do we protect your personal information
Vii. How do you manage your personal information (Your rights)
Viii. How do we handle the personal information of minors
Ix. Storage location and storage time of your personal information
X. Declaration of liability to third parties
Xii. How to contact us
Xiii. Description of key words in this policy
Xiv. Other Instructions
We understand the importance of personal information to you and will do our best to protect the security of your personal information. The personal information we collect, use, share, transfer and manage referred to in this Privacy Policy includes bold and underlined sensitive personal information and other personal information. We are committed to maintaining your trust in us and abide by the following principles: the principle of consistency of power and responsibility, the principle of clear purpose, the principle of choice consent, the principle of minimum necessary, the principle of ensuring safety, the principle of subject participation, the principle of openness and transparency, etc. At the same time, we promise to take appropriate security measures to protect your personal information according to the mature security standards of the industry.
Please carefully read and confirm that you have fully understood the content stated in this policy before using our products or services. You shall be deemed to accept the content of this policy after clicking "Agree" in the APP Privacy Policy Agreement pop-up window.
I. How do we collect your Personal information
(1) Connection services
To help you understand and diagnose your connection status with the Service, we will collect your wireless network and Internet connection status.
(2) Service optimization and security
In order to protect your normal use of our services, maintain the normal operation of our services, ensure the safety of your use of our products, and improve and optimize your service experience, we will not collect your information when you use the SmartKey.
(3) Application update reminder
In order to help you better experience our APP service, we will check whether there is a version update and remind you to update. We will get your software installation list to determine whether you have installed the APP market. If you agree to update this version, we will jump to the app market you have installed to update our app.
(4) When dealing with complaints, reports and other disputes between users, in order to deal with reports objectively and fairly. We may invoke relevant data for corroboration.
(5) Instructions on access to our APP permissions.
When you use our products or services, we may require you to grant the following permissions:
1. Network permission: When you use the "SmartKey", we will apply to you for this permission, in order to obtain network information and provide you with fast services. If you refuse to provide this permission, you may not be able to connect to the Mall, but it will not affect your continued use of other services.
You can always visit the system "Settings" to manage your system permissions, so as to better provide services for you.
(VI) Collection and Use of Personal Information without Consent According to laws, regulations and relevant national standards, we do not need your authorization and consent to collect and use your personal information in any one or more of the following circumstances, and we may not respond to your request to change, modify, delete, cancel, withdraw consent or request for information:
1. Those directly related to national security and national defense security;
2. Those directly related to public security, public health and major public interests;
Vii. How do you manage your personal information (Your rights)
We attach great importance to your management of your personal information. In accordance with the relevant laws, regulations, national standards of the People's Republic of China and common industry practices, we guarantee that you exercise the following rights to your personal information. The scope and method of your access, modification and deletion of your personal information will depend on the specific services you use:
(I) Manage the scope of your authorization
1. Each business function requires some basic personal information to be completed. You may at any time give or withdraw your authorized consent for the collection and use of additional collected personal information.
You can do this yourself by:
You can change the scope of your authorization in features and services by deleting information, turning off device features, and using Settings in the product client application.
Specific business functions and services will require your personal information to be completed. When you withdraw your consent, we cannot continue to provide you with the functions and services corresponding to the withdrawal of consent, and we will no longer process your relevant personal information. However, your decision to withdraw your consent will not affect our previous processing of personal information based on your consent. When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw consent will not affect the processing of personal information previously carried out based on your authorization. We will reply to your request to withdraw authorization within 15 working days.
(II) Constraint information System Automatic decision Making In some business functions, we may only make decisions based on non-human automatic decision making mechanisms such as information systems, algorithms, etc. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us to explain, we will also not infringe SmartKey trade secrets or other user rights, social public interests under the premise of providing appropriate remedies.
(III) How do we respond to your request
For security purposes, you may need to provide a written request or otherwise prove your identity. We may first ask you to verify your identity before processing your request.
We'll give you a reply within thirty working days. For your reasonable request, we will not charge fees in principle, but for repeated, beyond the reasonable limit of the request, we will charge a certain cost. We may reject requests that are unreasonably repetitive, require excessive technical effort (e.g., require the development of new systems or fundamental changes to existing practices), pose a risk to the legitimate interests of others, or are highly impractical.
1. Directly related to national security and national defense security; :
2. Those directly related to public security, public health and major public interests; :
3. Those directly related to criminal investigation, prosecution, trial and execution of judgment; :
4. There is sufficient evidence to show that you have 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. Involving trade secrets. :
(4) Complaints and reports
If you think that your personal information rights may be infringed, or find clues that your personal information rights may be infringed, you can report through the following ways, and we will respond to your complaint and report within 15 working days after verification:
1. Click [Setting-Question and Feedback] to contact us;
(5) Access privacy policy
You can view the full content of this policy after opening the SmartKey page for the first time or clicking "Settings", "About Us" and "Privacy Policy" after opening the SmartKey.
(VI) The right to inform you of the cessation of operation
If we cease operation, we will promptly stop the activities of collecting your personal information, notify you of the notice of cessation of operation by delivery or announcement one by one, and delete or anonymize your personal information held by us.
Viii. How do we handle the personal information of minors
(I) We attach great importance to the protection of personal information of minors. Our services are available to adults over the age of 18 (not students). If you are a minor under the age of 18, we recommend that you do not use our services. :
(2) If you must use our services, you should obtain written consent from your parents or legal guardians in advance or use your parents or legal guardians to operate on your behalf. We will protect the personal information of minors in accordance with relevant national laws and regulations.
(III) In the case of collecting personal information of minors with the consent of parents or legal guardians, we will only use or publicly disclose such information when permitted by law, with the explicit consent of parents or legal guardians or necessary to protect minors.
(IV) If you are the guardian of a minor, please contact us in time when you have any questions about the personal information of the minor under your custody.
(v) If we find that we have collected personal information from minors without the prior consent of a verifiable parent or legal guardian, we will try to delete the relevant data as soon as possible.
Ix. Storage location and storage time of your personal information
(1) Personal information collected and generated by us within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. We will not transmit the above information overseas. If some products involve cross-border business and we need to transmit the relevant personal information collected in China to overseas institutions, we will follow the relevant national regulations, ask for your consent, and carry out the implementation in accordance with laws and regulations and relevant regulatory authorities, and sign agreements, on-site verification and other effective measures. Require overseas organizations to keep your personal information confidential.
(II) We will only retain your personal information for the shortest time necessary to achieve the purpose of the Service, unless otherwise provided by laws and regulations or otherwise authorized by you. If the above retention period is exceeded, we will delete or anonymize your information.
(III) If we terminate the service or operation, we will notify you at least fifteen working days in advance, and delete or anonymize your personal information stored after the termination of the service or operation.
X. Declaration of liability to third parties
Please note that this policy only applies to the products or services provided by SmartKey to you.
If the third party service provider provides services to you through the SmartKey, when you enter the service page of the third party service provider, please note that the relevant services are provided to you by the third party. If a third party collects information from you, it is recommended that you carefully review the privacy policy or agreement of the third party. When you view the service pages of third parties (including applications developed by third parties or web pages created by third parties), these third parties may place their own cookies or similar technologies, which are not under our control and whose use is not governed by this Policy. We will strive to require the aforementioned third-party subjects to take protective measures for your personal information. If you find that the above third-party applications (or web pages) are at risk, it is recommended that you immediately terminate the relevant operations.
(I) This Policy applies to all services of SmartKey, but some specific services will also apply to specific privacy protection policies (such as power of attorney, power of attorney). We will further explain to you and obtain your authorization consent before providing these specific services to you. If there is any inconsistency between the specific privacy protection Policy and this Policy, the specific privacy protection policy shall prevail. Where the specific privacy protection policy does not mention, this privacy protection Policy shall prevail.
(II) Our Personal information protection Policy may change. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any changes to this Policy on this page.
We also provide more prominent notifications for major changes. If there is a major change to this policy, we will make an official announcement or notify you by push notification, SMS or phone call, and obtain your express authorization consent for the changed privacy policy again after the update of this policy. In order for you to receive notifications in time, we recommend that you notify us when your mobile phone number is updated. If you click "Confirm" or "Next" after this Policy is revised and we notify you, it means that you have fully read, understood and accepted the revised Policy.
Material changes referred to in this Policy include but are not limited to:
1. Significant changes have taken place in our service model. Such as the purpose of processing personal information, the type of personal information processed, and the way of using personal information;
2. We have made significant changes in ownership structure, organizational structure, etc. Such as business adjustment, bankruptcy merger and acquisition caused by the owner change;
3. The main object of personal information sharing, transfer or public disclosure changes;
4. Significant changes in your rights to participate in the processing of personal information and the way in which you exercise them;
5. Our responsible department for handling personal information security, contact information and complaint channels have changed;
6. The personal information security impact assessment report indicates that there is a high risk.
Xii. How to contact us
(I) If you have any questions, comments or suggestions about this policy or your use of our services, you can contact us through the following ways:
Tel: +86 13712612657
Email: 1530337899@qq.com
(II) In order to protect your information request, we need to verify your identity before processing your question, but we will reply to you within 15 working days at most from the date of your question, comment or suggestion.
Xiii. Description of keywords in this policy
(1) SmartKey App products or services: refers to the products and services that we and our affiliates provide to you through client applications that are legally owned and operated and are marked with the name "SmartKey".
(2) Sensitive personal information: refers to personal information that, once disclosed, illegally provided or abused, may endanger personal and property safety, easily lead to personal reputation, physical and mental health damage or discriminatory treatment. The personal sensitive information in this policy includes ID card number, email address, various passwords (passwords, protection answers, digital certificates), personal biometric information, general record and content, personal health and physiological information, personal property information, bank account number, credit information, whereabouts, accommodation information, transaction information, and personal information of children under 14 years old (including) .
(3) Identity elements: refers to the information elements used by the product to identify you, such as your login name, password, SMS check code, telephone number, mobile phone number, ID number and personal biometric information (such as fingerprint information, face information).
(4) Non-personal information: refers to the technical processing of personal information (including anonymization, de-identification, etc.), so that the processed information cannot be identified as your personal identity alone or in combination with other information, and the processed information cannot be restored, and the processed information does not belong to your personal information in the legal sense. However, when the personal information is used in combination with the processed information, the combined information will be treated and protected as your personal information in accordance with this Policy.
(5) Individual User: refers to the individual user registered to use the SmartKey, hereinafter referred to as "you" or "end User".
Xiv. Other Instructions
(I) The headings in this Policy are for convenience and readability only and do not affect the meaning or interpretation of any provisions in this Policy.
(II) Our products described in this policy may be different according to the phone model, system version, software application version and other factors used by you. The final products and services are subject to the products you use.
(III) The copyright of this policy is owned by us, and we have the right to modify it.
3. Those directly related to criminal investigation, prosecution, trial and execution of judgment;
4. For the purpose of safeguarding the life, property and other important legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain your consent;
5. The collected personal information is disclosed to the public by you;
6. Your personal information is collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;
7. It is necessary to sign or perform the contract according to your requirements;
8. It is necessary to maintain the safe and stable operation of the product, such as finding and handling product faults;
9. It is necessary for legal news reporting;
10. When it is necessary for an academic research institution to carry out statistical or academic research in the public interest and provide the results of academic research or description to the outside world, the personal information contained in the results is de-identified;
11. Other circumstances stipulated by laws and regulations and relevant national standards.
Ii. Purposes for which we collect and use your personal information
(I) We will only collect and use your personal information for the following purposes as described in this Policy
1. Ensure the normal operation of products and services;
2. Ensure the safety of products, services and users;
3. Realize personalized product functions or service requirements;
4. Evaluate and improve the effect of delivery and other promotional and promotional activities;
5, management software, such as software certification, software upgrade, etc.;
6. Comply with laws, regulations and national standards.
When we want to use personal information for other purposes not specified in this policy, we will seek your consent in advance. When we want to use the information collected for a specific purpose for other purposes, we will ask for your consent in advance.
(2) Changes in the purpose of collecting and using personal information
We may adjust the product as our business develops. When the new function or service is related to registration, login, connection, search, content recommendation and other scenarios, the personal information collected and used is directly related to the original purpose. When we collect and use your personal information without direct connection to the original purpose, we will ask for your consent again.
Iii. How do we use your personal information
(I) In order to comply with national laws, regulations and regulatory requirements, provide you with services and improve the quality of services, or protect the security of your account, we will use your information in the following situations:
1. To achieve the purposes described in "How We Collect Your Personal Information" in this Policy.
2. In order to let you know the status of using our service, we will send you service notices and reminders.
3. Report to relevant departments according to laws, regulations or regulatory requirements.
4. Invite you to participate in customer research related to our services.
5. In order to ensure the stability and security of the services, we will use your information for identity verification, security prevention, fraud detection, prevention or prohibition of illegal activities, risk reduction, archive and backup purposes.
6. When you apply for the products recommended by smart keys, we may need to generate your feature information based on rules or machine learning and other technical means. This kind of characteristic information is generated after anonymization or de-identification processing or sorting based on your information collected as listed in Article 1 of this Policy. This characteristic information will be used for anti-fraud and other purposes related to providing products or services to you.
(II) When we display your personal information, we will use de-identification processing to desensitize your information to protect your information security.
(III) When we want to use your personal information for other purposes not specified in this Policy, we will seek your explicit authorization and consent again through confirmation agreement, copy confirmation and other forms in accordance with the law. If you do not agree to the re-authorization, you may not be able to use the service, but it will not affect your use of other services.
How do we use cookies and similar technologies
(I) In order to ensure the normal operation of the website and make your access experience easier, we will store data files named cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. The main function of cookies is to facilitate your use of SmartKey products and services, and to help SmartKey websites count the number of unique visitors. Using Cookie technology, we can provide you with more thoughtful service.
(II) We will not use cookies for any purpose other than the purpose stated in this Privacy Policy. You can manage or delete cookies according to your preferences, you can clear all cookies saved on your computer or mobile device, and you have the right to accept or reject cookies. Most browsers automatically accept cookies, but you can usually modify your browser Settings to decline them if you want; Alternatively, you can clear all cookies stored in the software. However, you may not be able to fully experience some of our convenience and security service features.
V. How do we share, transfer and publicly disclose personal information
(I) How to share personal information
We will not share your personal information with any company, organization or individual
(2) How to transfer personal information
We will not transfer your personal information to any company, organization or individual.
(4) How to disclose personal information
We will only publicly disclose your personal information under the following circumstances and will adopt security measures in line with industry standards
1. After obtaining your explicit consent, disclose the personal information specified by you in the way of disclosure with your explicit consent;
2. Disclosure Based on law: We may publicly disclose your personal information under the mandatory requirements of laws, legal procedures, lawsuits or government authorities.
3. Punish illegal accounts and fraudulent behaviors.
(5) Personal information that is exempt from consent to be shared, transferred or publicly disclosed
In accordance with laws, regulations and national standards, we do not need your authorization to share, transfer or publicly disclose your personal information in the following circumstances:
1. Those directly related to national security and national defense security;
2. Those directly related to public security, public health and major public interests;
3. Those directly related to criminal investigation, prosecution, trial and execution of judgment;
4. For the protection of your or other individuals' life, property and other important legitimate rights and interests, but it is difficult to obtain your consent;
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;
7. It is related to the performance of obligations stipulated by laws and regulations by the personal data controller.
Vi. How do we protect personal information
The following personal information protection measures provided in this Policy only apply to our products. Once you leave our products, browse or use other websites, services and content resources, we have no ability and obligation to protect any personal information you submit to software, websites other than our products, regardless of whether you login, browse or use such software, websites based on links or guidance from our products
(I) To protect your information security, we are committed to using a variety of security technologies and supporting management systems to minimize the risk of your information being leaked, damaged, misused, unauthorized access, unauthorized disclosure and change.
We will take all reasonable and feasible measures to protect your personal information. For example:
1. The exchange of data between your device and the Product Service is protected by SSL encryption;
2. We will use encryption technology to ensure the confidentiality of data;
3. We use trusted protection mechanisms to protect our data from malicious attacks.
4. We will deploy access control mechanisms to ensure that only authorized personnel can access personal information;
5. We will hold security and privacy protection training courses to strengthen employees' awareness of the importance of protecting personal information;
6. Other protective measures that we consider reasonable and feasible.
(II) We will use reasonable and feasible means such as encryption technology and anonymization processing that are not lower than those of industry peers to protect your personal information, and use security protection mechanisms to prevent your personal information from malicious attacks.
(3) We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. We will only retain your personal information for as long as necessary to achieve the purposes set out in the policy, unless an extension of the retention period is required or permitted by law. We only retain your personal information for the period necessary for the purpose of providing products and services.
(4) The Internet is not an absolutely secure environment, and instant messaging and communication with other users are not encrypted. We strongly recommend that you do not send personal information through such means. Please help us keep your account safe by using a complex password. Please take good care of your product login name and other identity elements. When you use the Products, we will identify you by your login name and other identifying elements. Once you disclose the above information, you may suffer losses and may have adverse legal consequences. If you find that the product login name and/or other identity elements may or have been leaked, please contact us immediately, so that we can take appropriate measures in time to avoid or reduce the relevant losses.
(5) We will update and disclose the relevant content of the security risk and personal information security impact assessment report from time to time.
(6) The Internet environment is not 100% secure. We will try our best to ensure or guarantee the security of any information you send to 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 assume the corresponding legal responsibility.
(VII) After the unfortunate occurrence 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 measures we have taken or will take to deal with it, the suggestions for you to prevent and reduce the risk on your own, and the remedial measures for you. We will promptly inform you of the relevant information of the incident by email, phone, push notification, etc. When it is difficult to inform the personal information subject one by one, we will take a reasonable and effective way to publish the announcement. We will also take the initiative to report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.