Privacy Policy

 

Last updated on: 23rd July, 2020

Global Tone Communication Technology Co., Ltd. (registered address: 1601, 20 Shijingshan Road, Shijingshan District, Beijing, hereinafter referred to as “GTCOM” or “We”) attaches great importance to the protection of users’ personal information and privacy.

During your use of GTCOM’s products or services (hereinafter referred to as the “GTCOM Products”), we may collect and use your personal information. Considering this, we have formulated a privacy policy (this “Privacy Policy”) covering how users’ personal information is collected, stored, used, shared and protected. This Privacy Policy allows you to know why, how and to what extent we collect and use your personal information, your rights to your personal information, and the security measures we have taken to protect information security.

This Privacy Policy applies to services related to JoveBird (jovebird.com) (hereinafter collectively referred to as “JoveBird Platform”). Unless otherwise specified herein, this Privacy Policy is not applicable to any products and/or services provided to you by a third party independently that are accessed through our products and/or services, e.g. such products or websites as shown to you in search results, or such other websites linked to through our products and/or services. Please be aware that any personal information you provide to a third party during your use of its products and/or services is covered by the privacy statements or similar policies of such third party, and we are not liable for any improper use or disclose of your data by a third party.

You are explicitly requested to read this Privacy Policy carefully, in particular the words in bold, and not to use JoveBird Platform until you fully understand and consent to this Privacy Policy. You should cease to use JoveBird Platform immediately if anything contained herein is not acceptable to you.

This Privacy Policy will familiarize you with the following:

I.        How We Collect Your Personal information

II.      How We Use Cookies and Similar Technologies

III.    How We Use Your Personal information

IV.     How We Retain Your Personal information

V.       How We Transfer,Share and Public Disclose Your Personal information

VI.     How We Protect Your Personal information

VII.   Your Rights to Your Personal information

VIII. How We Process Personal information of Minors

IX.     Third Party Service Providers and Their Services

X.       How Your Personal information is Transferred Internationally

XI.     How this Privacy Policy is Updated

I.      How We Collect Your Personal information

“Personal information”, as used in this Privacy Policy, refers to all kinds of information recorded electronically or otherwise that can identify a natural person, alone or in combination with other information. “Sensitive Personal information” refers to personal information that, once divulged, illegally provided or misused, may endanger personal safety or property safety, or easily result in damage to personal reputation or physical and mental health, or discriminatory treatment.

We collect personal information in order to operate more efficiently and provide you with the best experience. We collect personal information from: (1) information you provide to us; and (2) information collected during your use of products or services.

The data we collect depends on the GTCOM Products you actually use, the environment in which you interact with us, and the choices you make, including your privacy settings and the products and functions you use. Our products and functions consist of core business functions and value-added business functions. You are not always required to provide your personal information to us when we collect them, but we may become unable to provide you with products or services or respond to or address your issues that are related to core business functions if you decide not to provide your personal information. As to functions other than core business functions, you may decide, at your own discretion, whether to consent to our collection of data, and if you refuse to give your consent, relevant business functions may become unfulfillable, which however has no impact on your use of our core business functions.

Please be aware that the functions and services we provide to you are subject to update and development. If any function or service not described below collects your information, we will inform you of the content, scope and purpose of such information collection by means of website popups, interactive processes, website announcements or execution of additional agreements etc., in order to obtain your consent.

1.       Information you provide to us

1.1    To create and maintain your service account

You should register for a service account with JoveBird Platform in order to access relevant services of JoveBird Platform. To this end, you need to provide your name or email address and corporate name to us, and set your account password. Such information is strictly needed for us to create an account for you. In case of your refusal to provide such information, we will be unable to create an account for you, or further provide you with the services available on JoveBird Platform.

When JoveBird Platform allow you to provide additional personal information (such as developing a personal profile), you may provide your phone number and profile photo etc. to us so that we can provide more personalized services to you. You may decide whether to provide such information or not at the time of registration or when you update your personal information. We do not compel you to provide such information, and your refusal to provide the same will have no impact on your use of the basic functions of JoveBird Platform.

For the purpose of providing certain functions (such as alert message or customer service) to you when you use JoveBird Platform, you are further required to provide contact information to us, including contact number and email address, to enable us to communicate with or give important notice to you or the corporate/institutional customer you represent. You will be unable to use such specific functions we provide if you fail to provide the foregoing information, but your access to the basic functions of JoveBird Platform will not be affected.

1.2    To guarantee your access to the product/service trial function

Trial function is available on JoveBird Platform. In order to provide product trial service to you, we need you to provide your user name, mobile phone number, company name, position and email address, for us to contact you and check and determine your eligibility for such trial service. Such information is strictly needed for us to provide you with trial service. In case of your refusal to provide such information, we will be unable to provide you with the trial service available on JoveBird Platform.

1.3    To guarantee your access to the feedback function

JoveBird offers feedback function. To enable you to give feedback to us, we will request and collect your personal information, including your name, mobile phone number, e-mail, address and your comments, so that we can reach you and inform you of our responses to your feedback. Your refusal to provide such information will prevent us from resolving and responding to your suggestions or requests in a prompt manner, but will have no impact on your use of the basic functions of JoveBird Platform.

1.4    To inform you of promotional activities

During your use of JoveBird Platform products, we may invite you to participate in our promotional activities such as questionnaire surveys. If you agree to participate in such activities, you will need to provide your name, mobile phone number or email address to us so that we can reach you with our questionnaires. If you refuse to provide the foregoing information, you may become unable to participate in our promotional activities, but your use of the basic functions of JoveBird Platform will not be affected.

2.       Information collected during your use of the products or services

We will collect some of your log information and operation records during your use of relevant products or services (including your use of relevant products or services through the account of your company/organization), in order to protect the security of JoveBird Platform and user accounts, offer better products and/or services and improve user experience:

Such information or records include information about your use of our products or services, your operations after logging on your account (including change of password or modification of linked mobile phone number, email address), search queries typed through the service, information about software events (such as restart, upgrade, error or failure), IP address, and the date, time and duration of access to the service and the information browsed.

Please be aware that the functions and services we provide to you are subject to update and development. If any function or service not described above collects your information, we will inform you of the content, scope and purpose of such information collection by means of website popups, interactive processes, website announcements or execution of additional agreements etc., in order to obtain your consent.

3.       Circumstances where personal information is collected and used without your consent

According to applicable laws, regulations and national standards, in any of the following circumstances, we may collect and use your personal information according to law without your consent:

(1)    Information in connection with GTCOM’s performance of its obligations under laws and regulations;

(2)    Information directly related to public health, and substantial public interests;

(3)    Information directly related to criminal investigation, prosecution, trial and execution of judgments;

(4)    Information collected to protect the life, property or other major legal rights of you or other individuals in the situation where it is difficult to obtain your consent;

(5)    The personal information concerned is disclosed to the public by yourself;

(6)    Information strictly required for execution and performance of contracts at your request;

(7)    Personal information sourced from legally and publicly disclosed information, such as legal news reports or information disclosed by the government;

(8)    Information necessary for maintaining the safe and stable operation of the products or services provided, such as identifying and resolving failures of products or services;

(9)    Information necessary for delivering news reports according to law;

(10) Information necessary for academic research institutions to collect statistics or conduct academic research in the public interest, provided that any personal information contained in the results of such academic research or descriptions thereof has been de-identified;

(11) Any other circumstances provided by laws and regulations.

II.   How We Use Cookies and Similar Technologies

Cookie is a neutral technology that allows web servers to store data on the users’ computers or read data from the users’ computers. We use Cookie technology to facilitate your quick and efficient use of our website products and/or services, and to help us calculate the number of unique visitors. Application of Cookie technology enables us to provide you with more thoughtful and personalized services and allow you to select specific service options.

One of the main purposes of Cookie is to provide practical functions in a time-efficient manner. For example, if you customize the webpage of JoveBird Platform, Cookie will help you invoke your information during subsequent visits, simplifying the process of recording your personal information (such as one-click login etc.). When you go back to JoveBird Platform, it may call up the information you previously provided, enabling you to easily use the functions you have customized. Technologies such as Cookie and web Beacon can help you optimize your selection about and interaction with advertisements.

When we carry out activities related to providing services on JoveBird Platform, we will use network Beacon to extract Cookie information on our websites. We will not obtain Cookie information about your visit to any platform or website other than JoveBird Platform.

You may reject Cookie by adjusting your browser settings. Certain functions of our products and/or services are in reliance upon Cookie, and if you reject or delete Cookie, you may be unable to log on or use some of our services or functions that are provided in reliance upon Cookie.

III.             How We Use Your Personal information

1.       Your personal information will be used in the application scenarios set out in “How We Collect Your Personal information” section.

2.       Your personal information may be used in the following scenarios that are directly or reasonably related to the purposes stated in the “How We Collect Your Personal information section”:

(1)    Provision and improvement of products and services: We will use the information collected to provide and improve the products and services provided by us or our affiliates, partners or other trustworthy third-party suppliers, service providers or agents, and to carry out necessary business operations, such as operating products or providing services, evaluating, maintaining or improving the performance of products or services, participating in market research activities concerning our products and services, developing new products or services, and providing customer support etc.

(2)    Statistical analysis of product usage: We may collect and analyze information on the use of products in order to improve our products and services or those of our affiliates, partners or other trustworthy third-party suppliers, service providers or agents. In addition, we may share these statistics with the public to show the overall trend in use of our services, but such statistics will not contain any information that can identify you.

(3)    Information and notification services: Alert message function is made available to you on JoveBird Platform. After you activate this function, we will forward alert messages to your mobile phone or email. If you do not want to receive any further alert messages, you may opt out of the function following the instructions provided in the alert messages or on JoveBird Platform.

3.       We may make comprehensive statistical analysis of the information we collect when you use JoveBird Platform, in combination with those shared by our affiliates or business partners upon your authorization or in accordance with laws and regulations, to better meet your requirements for personalization (e.g., enabling you to get more personalized recommendations). You agree to authorize us to share necessary data with our affiliates or other business partners in order to generally improve the personalization of the products or services provided to you.

4.       We may also conduct comprehensive analysis of the data collected, determine your account security, conduct identity verification, detect and prevent security incidents, and take necessary documentation, audit, analysis or disposal measures to better prevent phishing websites, deception, network vulnerabilities, computer viruses, network attacks, network intrusions or such other security risks, and improve the accuracy in identification of violations of laws and regulations or product/service-related agreements and rules, so as to protect the legitimate rights and benefits of you and other users, or those of GTCOM or our affiliates.

5.       Any use of your personal information to the extent not directly or reasonably related to the purposes stated in “How We Collect Your Personal information” section is subject to our further notice to you and your express consent.

IV.             How We Retain Your Personal information

The personal information we collect will be retained for the minimum period necessary for fulfilling the purposes herein stated for which they are collected, unless a longer retention period is provided by laws and regulations. Upon expiration of such retention period, we will delete or anonymize your personal information.

In case of termination of our products or services or any part thereof due to special reasons, we will promptly notify you, cease the collection and processing of personal information in connection with such products or services, and delete or anonymize any personal information in our possession that are related to such products or services, unless otherwise provided by laws and regulations.

V.   How We Transfer,Share and Public Disclose Your Personal information

In certain circumstances, we will appoint a third party to process your personal information on our behalf, such as companies that send text messages or emails, or provide technical support on our behalf, but they can use your personal information for the sole purpose of providing services to you on our behalf.

From time to time, we may share some personal information with our affiliates or strategic partners that work with us to provide the products and services you request.

1.       Sharing with affiliates: To the extent permitted by laws and regulations, your personal information may be shared with our affiliates, in order to comply with legal requirements, or prevent any damage to the interests, property or safety of GTCOM or our affiliates or partners, you or other users, or the general public, e.g. to prevent deception or any other illegal activities or reduce credit risk. We will only share such personal information as strictly necessary to fulfil the foregoing purposes. Without your consent, our affiliates will not use the personal information so shared for any purpose other than those stated above.

2.       Sharing with authorized partners: Solely for the purposes stated herein, some of our services will be provided with assistance from authorized partners. We may share some of your personal information with our partners so as to deliver better customer service and user experience. Our authorized partners include:

(1)    Cloud service providers: Some of our services will rely on third-party cloud service platforms. As a result, relevant business data will be stored on such platforms, and such third-party cloud service providers will collect information about your devices and network;

(2)    Third-party SDK service providers: If you use the alert message forwarding function on JoveBird Platform, we will fulfil relevant functions by using the software development kit (SDK) provided by a third party. Such third-party forwarding service providers may collect information about your devices, mobile phone status or network in order to forward alert messages that may be of more interest to you.

3.       In case of any merger, acquisition or bankruptcy and liquidation involving the transfer of personal information, we will cause the new company or organization taking possession of your personal information to be bound by this Privacy Policy, or otherwise obtain your authorization or consent. If transfer of personal information is not involved therein, we will keep you fully informed and delete or anonymize any and all personal information under our control. Internally, in previous acquisitions or mergers, any data (including user data) controlled by the acquired or merged entity will be processed and protected pursuant to the same standards and requirements as applicable to GTCOMs own data.

4.       We will enter into proper confidentiality agreements with any companies, organizations or individuals to whom personal information is shared, requiring them to use personal information solely for the purposes set out in this Privacy Policy and take relevant confidentiality and security measures to process personal information.

5.       We will keep your personal information confidential in accordance with applicable laws and regulations, and not disclose your personal information unless your express consent or authorization is obtained, or as required by law.

6.       In addition, according to applicable laws, regulations and national standards, in any of the following cases, we may share, transfer or disclose personal information without the prior authorization or consent of the data subject:

(1)    Information in connection with GTCOM’s performance of its obligations under laws and regulations;

(2)    Information directly related to public health, and substantial public interests;

(3)    Information directly related to criminal investigation, prosecution, trial and execution of judgments;

(4)    Information shared, transferred or disclosed to protect the life, property or other major legal rights of the data subject or other individuals in a situation where it is difficult to obtain the consent of the data subject;

(5)    Personal information disclosed to the public by the data subject;

(6)    Personal information sourced from legally and publicly disclosed information, such as legal news reports or information disclosed by the government.

VI.             How We Protect Your Personal information

1. To protect the security of your information, we will take technically reasonable and necessary measures to protect your information, and adopt physical, technological or administrative measures to reduce the risks of loss, misuse, or unauthorized access, disclosure or alteration. The measures include but not limited to transport layer encryption, firewalls and encrypted storage, physical access control and information access control. To this end, we have developed security procedures to protect your information from being stolen by unauthorized access. All personal information is encrypted and protected by a professional firewall.

2. To protect the security of your information, we have developed relevant systems, processes and organizations to protect information security. In particular, we put a strict limit on persons with the right to access information and require them to comply with confidentiality obligations.

3. When you use our services, please properly keep your account number and password, which will be used by us to identify you. Your disclosure of your account number and password to others may result in loss of your information or cause adverse legal consequences to you. If your account number and password have been or are to be disclosed for any reason, you should contact us immediately after you become aware of such disclosure, so that we can take prompt and proper measures to prevent or reduce losses arising therefrom.

4. Upon occurrence of divulgence of personal information or any other security incidents, we will initiate emergency response procedures to prevent the case from getting worse, and keep you informed by means of forwarding notifications or announcements etc.

5. The Internet environment is not 100% secure. We will use our best efforts to ensure or guarantee the security of any information you send to us. We will be liable for any damage to your legal rights and benefits resulting from unauthorized access, public disclosure, alteration or destruction of information due to any damage to our physical, technological or administrative protection facilities.

VII.          Your Rights to Your Personal Information

We respect your rights to your personal information. The following are your legitimate rights and how we will protect your rights.

1.       Right to Know: By publishing this Privacy Policy, we inform you how we process your personal information. We are committed to ensuring the transparency in the use of your information.

2.       Right of Access: You can query or access your personal information in our product or service interface, including that you can log on your account at any time through the product page to access your account related personal information, such as basic information, operating records, storage and download records. You can also browse your information about the use of products or services at any time. For example, you can access your history browsing records in your browser.

You can query and access your personal information by: [log on JoveBird Platform and go to “account settings” for query and access]

3.       Right of Correction: When you find that your personal information we are processing is incorrect or incomplete, you have the right to require us to make corrections or supplements. You may correct and modify some of your personal information directly on the relevant function page of the product or service. If you are not provided with channels to self-modify some personal information, you can also contact us through the contact information disclosed in this Privacy Policy to request correction or supplement of the information, and we will process and give feedback in time according to laws and regulations.

You can correct your personal information by: [log on JoveBird Platform and go to “account settings” for correction]

4.       Right to Delete: You can delete the specific information you submitted directly in the product interface through your account, such as profile and user name. If we collect and use your personal information in violation of our agreement with you, you can also contact us through the contact information disclosed in this Privacy Policy to request deletion, and we will process and make feedback in time according to laws and regulations.

You can delete your personal information by: [log on JoveBird Platform and go to “account settings” for deletion]

5.       Right to Cancel: You are provided with account cancellation service, which allows you to cancel your account in the product interface. After you choose to cancel your account, we will delete or anonymize all your relevant personal information according to laws and regulations, unless otherwise provided by laws and regulations. After the cancellation, we will not be able to continue to provide you with account registration services and products or services that require you to log on your account.

You can cancel your account by: [log on JoveBird Platform and go to “account settings”- “account cancellation”]

6.       Right to Withdraw Consent: Each business function requires some basic personal information to be completed (see “How We Collect and Use Your Personal Information” section of this Privacy Policy). You can change the scope of your authorization to continue collecting personal information or withdraw your authorization by deleting information, changing the relevant product or function setting page, account cancellation, etc.

You can change your authorization consent by: [log on JoveBird Platform, go to “alert page”-“close”, or go to “account settings” to change your authorization consent through information deletion, account cancellation, etc., or contact us through contact information disclosed in this Privacy Policy]

If you do not want to accept the commercials we sent you, you can cancel it at any time by: [contact us by sending an email to globalbiz@gtcom.com.cn].

If you withdraw your authorization consent, we will not be able to continue providing you with the services related to the consent withdrawal or authorization. When you withdraw your consent, we will no longer process the relevant personal information, but your decision to withdraw your consent will not affect the previous personal information processing activities based on your authorization.

7.       Right to Complain: You have the right to contact us for complaints through the contact information disclosed in this Privacy Policy. We will make a reply within 15 working days from the date of receipt of your complaint. If you are not satisfied with our reply, especially if our personal information processing behavior has damaged your legitimate rights and interests, you can also make complaints or reports to the regulatory authorities such as cyberspace, industry and commerce, or file a lawsuit to a court with jurisdiction.

Please note that we may verify your identity before processing your request for security reasons. For your reasonable request, we do not charge in principle. However, we will charge a certain cost for repeated request and request beyond reasonable limits as the case may be. We may reject requests that are unprovoked and repeated, which require too many technical means (e.g., to develop new systems or fundamentally change existing practices), pose a risk to the legitimate interests of others or are highly impractical. Furthermore, we may not be able to respond to your request if it relates directly to public health, crime investigation, and other matters directly related to the public interest, or may result in serious damage to the legitimate rights and interests of you or other individuals or organizations, or in circumstances related to the performance by GTCOM of its obligations under laws and regulations.

VIII.        How We Process Personal Information of Minors

Our products, websites and services are not for minors. If we collect the personal information of minors on an occasional basis, we will try to delete the relevant information as soon as possible after verification. If you find in the process of using JoveBird Platform that we have collected the personal information of minors, please contact us through the contact information published in this Privacy Policy. Upon receipt of your notice, we will verify it in a timely manner and delete relevant information after verification.

IX.             Third Party Service Providers and Their Services

Our websites, products, applications and services may contain links to third-party websites, products and services. You can choose whether to access or accept the websites, products and services provided by third parties. The social media links on the official website will guide you to access our official account in the social network platform, where you can learn about marketing or promotion information released by us.

We have no control over the privacy and data protection policies of third parties who are not bound by this Privacy Policy. Please check and understand the privacy protection policies of these third parties before submitting personal information to third parties.

X.    How Your Personal Information Is Transferred Globally

In principle, the personal information we collect and generate in China will be stored within Chinese territory. If partial products or services are cross-border, we need to transmit your personal information overseas, and we will strictly follow the provisions of applicable laws and regulations, and ensure your personal information security.

XI.             How this Privacy Policy Is Updated

Our Privacy Policy may be revised in the event of major changes. We will not limit your rights under this Privacy Policy without your explicit consent. We will post any revisions to the Privacy Policy on a dedicated page. If you continue to choose to use our products or services, you agree to be bound by the updated Privacy Policy and its related policies.

For major revisions, we will also provide more prominent notices (including for some services, we will notify you of any changes to our Privacy Policy by posting them on our website).

Significant changes referred to in this Privacy Policy include, but are not limited to:

(1)    Significant changes have taken place in our service pattern. For example, the purpose of users’ information processing, the type of users’ information processed, the use of users’ information, etc.;

(2)    We have significant changes in control, equity structure, organizational structure, etc. For example, the change of owners caused by business adjustment, bankruptcy, M&A and so on;

(3)    Changes have taken place in the main objects of users’ information sharing, transfer or public disclosure;

(4)    Significant changes have taken place in your right to participate in users’ information processing and the way it is exercised;

(5)    Changes have taken place in our users’ information security department, contact information and complaint channels.

This Privacy Policy takes effect from the date of update.

If you have complaints and reports about network information security, or if you have any questions, opinions or suggestions regarding this Privacy Policy and your information, and for matters related to this Statement or GTCOM’s privacy measures, please contact us through the following contact information, and we will handle it and give feedback in time according to laws and regulations.

Email: globalbiz@gtcom.com.cn

Tel: +1(408)540-3745