JoveBird Privacy Policy
Updated
on: 19th April 2021
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 data 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 data. Considering this, we
have formulated a privacy policy (this “Privacy Policy”) covering how users’
personal data 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 data, your rights to your personal data, 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.
It should be noted that if you provide your personal data to any
third party when using its products and/or services, your information shall be
subject to the privacy statement or similar policies of such third party, and
we will not undertake any legal liability for any third party’s improper use or
disclosure of such information.
Please carefully read and fully understand the
Privacy Policy, and click
or tick “agree” to give your consent before using JoveBird
Platform, with special attention paid to the bold parts. If you disagree with
any content thereof, please stop using JoveBird
Platform immediately.
This Privacy
Policy will familiarize you with the following:
I.
How We Collect Your Personal Data
II.
How We Use Cookies and Similar
Technologies
III.
How We Use Your Personal Data
IV.
How We Retain Your Personal Data
V.
How We Share, Transfer and Publicly Disclose Your Personal Data
VI.
How We Protect Your Personal Data
VII.
Your Rights to Your Personal Data
VIII.
How We Process Children’s Personal Data
IX.
Third Party Service Providers and Their
Services
X.
How Your Personal Data is Transferred
Globally
XI.
How this Privacy Policy is Updated
XII.
Special Notice Based on CCPA
I.
How
We Collect Your Personal Data
“Personal
data” hereunder refers to any information relating to an identified or
identifiable natural person.
We
collect personal data in order to operate more efficiently and provide you with
the best experience. We collect personal data from: (1) information you provide
to us; and (2) information collected during your use of products or services.
The information
we collected depends on the GTCOM Products you actually used, the environment
in which you interact with us, and the choices you made, including your privacy
settings and the products and functions you used. Our
products and functions consist of core business functions and value-added
business functions. It is not your
obligation to provide us with your personal data upon our request. However, if
you choose not to provide your personal data needed for core business
functions, we may not be able to provide you with relevant products or
services, nor respond to or solve your problems. For non-core business
functions, you may choose to disagree with our collection of your personal
data. In that case, you may not enjoy relevant business
functions, without any impact on your experiences of our core business
functions.
Please
understand
that the functions and services we provide to you are constantly updated
and developed. Where
specific functions or services are not contained in the following description,
but we collect your information when you use such functions or services, we’ll
explain to you the content, scope and purpose of such collection through page
prompt, interactive process, website announcement, extra agreement, or by other
means, so as to obtain your consent.
1.
Information
you provide to us
1.1 To create and maintain your service account
You
need to register a JoveBird Platform service account
in order to use the services of JoveBird Platform. To
this end, you need to provide your name or e-mail 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.
Where
any GTCOM Products allow you to provide additional personal data (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 data. 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 e-mail 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, you need to provide your user name,
mobile phone number, company name, your position and your e-mail address, for
us to contact you and review 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. If you would like to give feedback to us, you may need to provide us
with your personal data, including your name, mobile phone number, e-mail address,
your contact address and your comments, so that we can contact you and respond
to you regarding your comments in a prompt manner. Your refusal to provide such information will prevent us from figuring
out and responding to your suggestions or requests in a prompt manner, without any 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 e-mail address to us so that we can contact you
and provide you with our questionnaires. If
you refuse to provide the foregoing information, you may not be able 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
In
order to protect the security of JoveBird Platform
and user accounts, offer better products and/or services and improve user
experience, we may need to 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 under the account of your company/organization).
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 or e-mail address,
and appeal records), search queries
typed through the service, information about software events (such as restart,
upgrade, error or failure), Internet Protocol (IP) address, URL of the service accessed,
type of and language used by the browser, information about downloading,
installation or use of mobile applications and software, communications with
communication software, and the date, time and duration of access to the
service and the information browsed.
II.
How We Use Cookies and Similar Technologies
1.
What are
cookies?
The main function of cookies is to facilitate your
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.
2.
Cookies we used
One of the main purposes of cookies is to provide
practical functions in a time-efficient manner. For example, if you customize
the webpage of JoveBird Platform or use multiple
services of JoveBird Platform, cookies will help you
invoke your information during subsequent visits, simplifying the process of
recording your personal data (such as one-click login etc.). When you go back
to the homepage of JoveBird Platform, it may call up
the information you previously provided, enabling you to easily use the
functions you have customized.
Technologies such as cookies and web beacons can
help you optimize your selection about and interaction with advertisements.
When we carry out activities related to products and
services on JoveBird Platform, we will use network
beacon to extract cookies on our websites.
Meanwhile, we also use cookie or similar tracking
technologies to analyze trends, manage websites, track user behavior on
websites, and collect information about the overall audience characteristics of
our user group. We automatically collect certain information to analyze
cumulative trends and manage our website. Such information may include IP
address, type of browsers, Internet Service Provider (ISP), reference/exit
page, files you view on our website (e.g., HTML pages, graphics, etc.),
operating system, date/time stamp, and/or clickstream data.
3.
Clear/disable cookies
In principle, we
will only enable cookies or similar technologies after obtaining your explicit
consent, and collect your information through cookie. You can turn on the
cookie related functions or perform corresponding operations through methods to
manage cookies or set cookie preferences in commonly used browser software disclosed
below. We will strictly follow your decision to use cookies and similar
technologies.
Certain
functions of our products and/or services depend on cookies, and if you reject
or delete cookies, you may be unable to log on or use our services or functions
that are provided depend on cookie. The guidance on how to disable, delete or
manage cookies in commonly used browser software is detailed as follows:
4.
More Information about the
cookies
For more information about the cookie and
instructions on the setting of your browser to accept, delete, or disable the
cookie, see
www.allaboutcookies.org. You can also visit our
Cookie Policy for more
information.
III.
How We Use Your Personal Data
When we fulfill our
obligations to you under the User Agreement and/or the Service Contract, or
legal obligations bound to us, or we consider it necessary to protect the
legitimate interests of us or third parties upon evaluation, we will process
your personal data for the purposes described herein subject to your consent.
We will use your personal data in strict accordance with this Privacy Policy
and its updated versions. Your personal data is only used for the purposes
explicitly stated upon collection and to the extent you agreed. For any purposes other than that, we will
seek your prior consent.
1.
Your personal data will be used in the
scenarios set out in “How We Collect Your Personal Data” section.
2.
Your personal data may be used in the
following scenarios that are directly or reasonably related to the purposes
stated in the “How We Collect Your Personal Data” 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 do not contain any information that may reveal your identity.
（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
you via your mobile phone or e-mail address. 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 conduct comprehensive statistical analysis of the information we
collect when you use different GTCOM Products, in combination with those shared
by our affiliates or business partners upon your authorization or other legal
basis, thus better satisfying your personalized demands (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 and transaction risks based on
your trading practices and commonly used software, 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 data to the extent beyond the purposes disclosed in the Privacy Policy is subject to our further notice to you
and your explicit consent.
IV.
How We Retain Your Personal Data
The personal data 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 data.
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 data in connection with such products or
services, and delete or anonymize any personal data in our possession that are
related to such products or services, unless otherwise provided by laws and
regulations.
V.
How
We Share, Transfer and Publicly Disclose Your Personal Data
In certain circumstances, we will entrust a third party to process your personal
data on our behalf, such as companies that send text messages or e-mails,
or provide technical support on our behalf, but they can use your personal data
for the sole purpose of providing services to you on our behalf.
From time to time, we may share some personal data 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 data may be shared
with our affiliates, in order to comply with the laws, 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 data as strictly necessary to fulfill the
foregoing purposes. Without your consent, our affiliates will not use
the personal data 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 certain
of your personal data with our partners so as to deliver better customer
service and user experience. Our authorized partners include the following
types:
(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 fulfill 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 and network related information 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 data, we will cause the new company or
organization taking possession of your personal data to be bound by this
Privacy Policy, or otherwise obtain your authorization or consent. If transfer
of personal data is not involved therein, we will keep you fully informed and
delete or anonymize any and all personal data 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 GTCOM’s own data.
4.
We will enter into proper confidentiality
agreements with any companies, organizations or individuals to whom personal
data is shared, requiring them to use personal data solely for the purposes set
out in this Privacy Policy and take relevant confidentiality and security
measures to process personal data.
5.
We will keep your personal data
confidential in accordance with applicable laws and regulations, and not
disclose your personal data unless your explicit consent or authorization is
obtained, or as required by law. We may only disclose your personal data as
demanded by law, subpoena or other legal procedures, litigation or mandatory
requirements of government authorities. If we sincerely believe that disclosure
is necessary to protect our rights, the safety of you or others, investigate
fraud or respond to government requirements, we may disclose your personal data
publicly.
VI.
How We Protect Your Personal Data
1．To protect the security of your information, we will take
technically reasonable and necessary measures to protect your information under the current development
level of technologies, and adopt physical,
technological or administrative measures to reduce the risks of loss, misuse,
or unauthorized access, disclosure or change of data. The measures include but
are 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 data 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 data 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 Data
We respect your rights to your personal data. 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 data. We are committed to ensuring the transparency in
the use of your information.
2.
Right to access: You can query or access your personal data 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 data, 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. If
you are unable to self-query or access your personal data, or encounter any
problems in exercising your right to access, you can contact us through the
contact information disclosed in this Privacy Policy to request access, and we
will process and give feedback in time according to laws and regulations.
You can query and access your personal data by: [log on JoveBird Platform and go to “account settings” for query
and access]
3.
Right to rectification: When you find that your personal data that
we are processing is incorrect or incomplete, you have the right to require us
to make rectifications or supplements. You may rectify and modify some of your
personal data directly on the relevant function page of the product or service.
If you are not provided with channels to self-modify some personal data, you
can also contact us through the contact information disclosed in this Privacy
Policy to request rectification or supplement of the information, and we will
process and give feedback in time according to laws and regulations.
You can rectify your personal data by: [log on JoveBird Platform and go to “account settings” for correction]
4.
Right to erasure/deletion: 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 data in violation of our agreement with you, you can also contact us
through the contact information disclosed in this Privacy Policy to request erasure/deletion, and we will
process and make feedback in time according to laws and regulations.
You
can erasure/delete your personal data by: [log on JoveBird
Platform and go to “account settings” for deletion]
5.
Right to cancel
account: 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
data 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 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 restriction of
processing: You have the right to require us
to restrict our processing of your personal data, which means that we can store
it, but we cannot process it any further. We wil only
keep the data required to respond to your future request. You can also contact
us through the contact information disclosed in this Privacy Policy to exercise
your right to restriction of processing, and we will process and make feedback
in time according to laws and regulations.
You
can realize your right to restriction of processing by: [reaching us by
sending an e-mail to support@gtcom-us.com]
7.
Right to data
portability: To the extent permitted by laws
and regulations, you have the right to obtain your personal information in
structured, commonly used and machine-readable formats. For example, if you
decide to change to a new service provider, the right allows you to reliably and safely move and copy or easily transfer your
personal data between our IT system and their IT system without affecting its
use.
After
providing formal authorization, you can realize your right to data portability
by sending an e-mail to the following address: [support@gtcom-us.com]
8.
Right to object: Even if the processing of your data is based on our
legitimate interests, the exercise of public power, direct marketing (including
data aggregation), and statistical reasons, you have the right to object the
processing of your personal data by GTCOM.
You
can realize your right to object by sending an e-mail to the following address:
[support@gtcom-us.com]
9.
Right to withdraw consent: Certain basic personal data is
required for realizing each business function (see “How We
Collect and Use Your personal data” section of this Privacy Policy). You can change the scope of your consent for us to
continue collecting personal data or withdraw your consent by deleting
information, changing the relevant product or function setting page, or
cancelling your account, etc.
You can change
your consent by: [log on JoveBird Platform, go to
“alert page”-“close”, or go to “account settings” to change your 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 commercial advertisements
we sent you, you can cancel it at any time by: [sending an e-mail
to support@gtcom-us.com].
If
you withdraw your consent, we will not be able to continue providing you with the
services that you have withdrawn your
consent. When you withdraw your consent, we will no longer process
the relevant personal data, but your decision to withdraw your consent will not
affect the previous personal data processing activities based on your
authorization consent.
10. Right to refuse automated decision-making: You have the right not to be subject to a decision based
solely on automated processing, including user profiling. If these decisions
significantly affect your legal rights, you can reject the automated
decision-making by sending an e-mail to the following address [support@gtcom-us.com],
and we will respond to your request and take appropriate measures as needed.
11.
Right to complain: You have the right to contact us for complaints through the
contact information disclosed herein, or to make a complaint with the data
protection agency of your country about our processing of your personal
data.
We will respond
to your request and communicate with you in an appropriate way within 30 days
from the date of receiving your request. If necessary, we may extend the
aforementioned period (up to 30 days) and inform you of the reasons for the
extension within 30 days from the date of receiving your request. If we have
good reason to believe that there is no need to take any action on your
request, we will inform you of our decision and give you an explanation within
30 days from the date of receiving your request. If you are not satisfied with
our reply, you can also make complaints or reports to the supervisory
authorities in your jurisdiction, or file a lawsuit to a court with
jurisdiction.
VIII.
How
We Process Children’s
Personal Data
Our products,
website and services are not intended for children under the age of 16 (or as
required by applicable laws and regulations in your jurisdiction). If we
collect the personal data of children on an occasional basis, we will delete
the relevant information as soon as possible after verification. If you find
that we have collected the personal data of children during your usage of JoveBird Platform, 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
1.
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 “About Us” function on the official website of
GTCOM 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.
2.
We have no control over the privacy and
data protection policies of these 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 data to third parties.
X.
How Your Personal Data Is Transferred Globally
1.
As we provide JoveBird
products and services globally, your personal data (including the types of
information we listed in the section “How We Collect Your Personal Data”) may
be transferred by us to jurisdictions other than the countries/regions in which
you use the product or be subject to access from these jurisdictions, as
required by global business need. For
example, the data generated and collected during your use of JoveBird Platform (including the information listed in the
Clause “How Do We Collect Your Personal Data”) will be stored in Mainland
China.
2.
When your personal data
is transmitted to countries outside the European Economic Area, we will ensure
that appropriate protection measures are taken. For example:
(1)
The country or region
where the personal data recipient is located benefits from the adequacy
decision of the European Commission under Article 45 of the General Data
Protection Regulation (“GDPR”); or
(2)
The personal data recipient has signed
the standard data protection contractual clauses approved or adopted by the
European Commission according to Article 46 of GDPR.
3.
In the absence of the
aforementioned appropriate protection measures, we will request your explicit consent to
cross-border transfer
of personal data, and implement security measures such as encryption or
de-identification to protect your personal data.
4.
If you would like to obtain a copy of
standard data protection contractual clauses, or learn more about the
protection measures related to the transfer of your personal data outside the
European Economic Area, please contact us via sending an e-mail to
[support@gtcom-us.com].
XI.
How this Privacy Policy is Updated
1.
The
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 will be deemed to have
agreed to be bound by the updated Privacy Policy and its related policies.
2.
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).
3.
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 personal data
processing, the type of users’ information processed, the use of personal data, etc.;
(2)
We have significant changes in control,
equity structure, organizational structure, etc. For example, the change of
owners caused by business adjustment, bankruptcy, merger and acquisition and so
on;
(3)
Changes of the types of main subjects to
which the sharing, transfer or public disclosure of personal data is made;
(4)
Material changes of your rights relating
to your participation in personal data processing or the way in which such
rights may be exercised; and
(5)
Changes in our department responsible
for the security of personal data processing or changes of our contact
information or complaint channel
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, or any matters related to this Privacy Policy 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.
Address:
E-mail: [support@gtcom-us.com]
You
can contact our Data Protection Officer (DPO) by:
E-mail: [security@gtcom.com.cn]
XII.Special
Notice Based on CCPA
Please refer to Appendix 1.
Appendix
1: Special Notice Based on California Consumer Privacy Act
As supplementary terms to the JoveBird
Privacy Policy, the Special Notice constitutes an integral part of the JoveBird Privacy Policy and is applicable to residents in the State of California who visit and use JoveBird
Platform (hereinafter referred to as “California residents” or “You”).
We adopt this notice to comply with the
California Consumer Privacy Act of 2018 ("CCPA"). The
last update date of the Special Notice is 19th April 2021.
The Special Notice will explain to you:
1. The
categories and sources of your personal information we collected in the past 12
months
2. The
purpose of our collection of your personal information
3. The
situation of our sharing of your personal information for business purposes in
the past 12 months
4. No
sale of personal information
5. Your
rights under the CCPA
6. The
principle of non-discrimination
7. California
Shine The Light Law
The “Personal Information” mentioned herein refers
to the information that identifies, relates to, describes, is reasonably
capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular consumer or household. Please
read this Special Notice carefully to understand our practices on customer’s
personal information and privacy protection before using our products (or
services) or providing personal information to us.
1. The
categories and sources of your personal information we collected in the past 12
months
You have the right to know the categories of
personal information we may collect from you and the specific purpose for which
we collect it. Your personal information we collected in the past 12 months and
its sources are as below:
（1） Personal
information you may provide to us, including:
-
Identifiers,
such as name, telephone number, e-mail address, home address and IP address;
-
Biometric
information: for example, your profile photo uploaded which may contain your
facial information; and
-
Professional
or employment-related information, such as your company name and your position.
（2）
Personal information
we may collect during your use of JoveBird Platform,
including:
-
Internet
or other electronic network activity information: including 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, e-mail
address or appeal records), search queries typed through the service,
information about software events (such as restart, upgrade, error or failure),
Internet
Protocol (IP) address, URL of the service accessed, type of and language used
by the browser, information about downloading, installation or use of mobile
applications and software, communications with communication software, and the
date, time and duration of access to the service and the information browsed.
2. The
purpose of our collection of your personal information
Your personal information collected by us is mainly
used:
(1)
To create and maintain
your service account:
-
We
will use the name, e-mail
address and company name you provide, and account password you set to create a
service account for you.
-
Your
phone number and profile photo etc. provided to us will be used in a manner so
that we can provide more personalized services to you (such as creating a
personal profile).
(2)
To
provide 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
e-mail.
(3)
To
provide trial products or services: We will contact you according to
your user name, mobile phone number, company name, position and e-mail address
that you have provided to us, and review and determine your eligibility for
such trial products or services.
(4)
To
provide and improve 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 trusted 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.
(5)
To
protect the security of JoveBird Platform and user
accounts, and improve the user experience: 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. We
will also comprehensively analyze the information collected, judge your account
security and transaction risks based on your trading habits and commonly used
software, verify and detect your identity, and take preventive measures for
security incidents. In the meantime, we will take necessary recording,
auditing, analysis and disposal measures according to the law for better
prevention of security risks (including phishing website, fraud, network
vulnerabilities, computer viruses, cyber-attacks and network intrusions) and
more accurate identification of violations against laws and regulations or
product and service-related agreements and rules, thus protecting legal
interests of all parties.
(6)
To conduct
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 trusted third-party
suppliers, service providers or agents. Meanwhile, we may share these statistics with the
public to show the overall usage trend of our services, provided that these statistics
do not contain any information that may reveal your identity.
(7)
To
enable you to give feedback to us: We will reach you and inform you of our responses
to your feedback according to your personal information (including your name,
mobile phone number, e-mail
address, address and your comments) provided by you and
collected by us.
(8)
To
provide you with promotional activities: During your use of JoveBird Platform products, we may invite you to
participate in our promotional activities such as questionnaire surveys. We
will use your name, mobile phone number or e-mail address provided by you to us
to contact you and send you a questionnaire at your discretion.
(9)
To respond to law
enforcement requests according to applicable laws,
court orders or government regulations.
Without your consent,
we will not collect any personal information other than those as disclosed
herein, or use the personal information collected by us for any purposes other
than those as mentioned above.
3. The
situation of our sharing of your personal information for business purposes in
the past 12 months
You have the right to know whether your personal
information is shared with any third party. We may disclose your personal
information to third parties for business purpose. We will enter into
agreements with such third parties for the realization of such business
purposes, requiring them to undertake confidentiality obligations in respect of
the personal information we disclose to them, and not to use the personal
information for any purpose other than those stipulated herein.
The details of your personal information we have
shared over the past 12 months are as follows:
(1)
Identifiers:
-
In
order to prevent illegal activities such as fraud and reduce credit risk, your
personal information may have been shared with our affiliates.
-
Some
of our services 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 may have collected information about your devices.
-
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 in order to forward
messages that may be of more interest to you.
(2)
Internet or other
electronic network activity information:
-
In
order to prevent illegal activities such as fraud and reduce credit risk, your
personal information may have been shared with our affiliates.
-
Some
of our services 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 may have collected network-related information;
-
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 mobile phone status and network
related information in order to forward alert messages that may be of more
interest to you.
4. No
sale of personal information
You have the right to know whether your personal
information is sold or not. As defined in CCPA, “sell,” “selling,” “sale,” or
“sold,” means selling, renting, releasing, disclosing, disseminating, making
available, transferring, or otherwise communicating orally, in writing, or by
electronic or other means, a consumer’s personal information by the business to
another business or a third party for monetary or other valuable consideration.
We do not sell personal
information. None of your personal information has been sold by us in the past
12 months.
5. Your
rights under the CCPA
(1)
Your rights
According to the
provisions of the CCPA, you are entitled to the following rights:
-
Right
to know/access: To understand the situation of our collection and
using of your personal information in the past 12 months.
-
Right
of data portability: To obtain a copy of your personal information.
-
Right
to request deletion: To erase/delete your personal information.
-
Right to opt-out of
the sale of personal information: we do not provide opt-out mechanism as we do
not sell your personal information.
(2)
Method to request
rights
You can exercise your rights through the following
method. Once we receive and verify your request, we will respond according to
the requirements of CCPA:
-
E-mail:
[support@gtcom-us.com]
(3)
Exercise of Your
Rights
Please be aware that only you or a person registered
with the California Secretary of State that authorized by you to act on your
behalf may make a verifiable request relating to your personal information. You
may also make a verifiable request on behalf of your minor children.
Please be noted that
according to the provisions of the CCPA, we are not obligated to respond to request
for access or data portability of the same consumer more than twice in a
12-month period.
We may deny your
deletion request if it is necessary for us or our service providers to retain
your information based on the following circumstances:
-
To complete a
transaction to collect personal information, perform a written warranty or
product recall term under the federal law, provide the goods or services you
require or reasonably expect in our ongoing business relationship with you, or
perform a contract between us and you.
-
To detect security
incidents against malicious, deceptive, fraudulent or illegal activities; or
prosecute those responsible for such activities.
-
To debug products to identify and
repair errors that impair existing intended functionality.
-
To exercise freedom of
speech, safeguard another consumer’s right to exercise the right to freedom of
speech, or to exercise another right prescribed by law.
-
To abide by California
Electronic Communications Privacy Act in accordance with Chapter 3.6 of
Title 12 of Part 2 of the California
Penal Code
(commencing with Section §1546).
-
If you have provided
your informed consent to engage in public or peer-reviewed scientific,
historical or statistical research that complies with all other applicable
ethical and privacy laws in the public interest, and the erasure/deletion of
information may result in the inability or serious impairment of the results of
such research.
-
To only allow internal
use based on our relationship with you and such internal use is reasonably
consistent with your expectations.
-
To comply with the
obligations as stipulated by law.
-
To use your personal
information internally in a legal manner appropriate to the environment in
which you provide the information.
(4)
Respond to your
request
Before responding to your request, we may need to
verify your identity and authenticity of request. A verifiable consumer request
shall:
-
Provide
sufficient information to enable us to reasonably verify that you are the
person or authorized representative whose personal information we collect.
-
Describe
your request in detail so that we can understand, evaluate and respond
correctly.
If we are unable to
verify your identity or access to make a request and confirm that the personal information
is relevant to you, we will not be able to respond to your request or provide
you with personal information.
We will respond to your
request within 45 days after receiving your verifiable request. If we need more
time (up to 90 days), we will inform you in writing of the reason and extension
period. If you are our registered user, we will send a written reply to your
registered account. If you are not registered, we will provide a written reply
by mail or electronic means according to your choice.
Responded information
provided by us will only cover 12 months prior to the receipt of verifiable
requests. If we decide to reject your request, the reply we provide will
explain the reason of our rejection. For your request to the right of data
portability, we will choose a format to provide easy-to-use personal
information and allow you to transfer the information from one entity to
another without difficulties.
We will not charge to
process or respond to your request unless your request is excessive, repetitive,
or manifestly unfounded. If we determine that a fee can be
charged in response to your request, we will inform you of the reason for the
charge and provide you with an estimated amount before replying to your
request.
6. The
principle of non-discrimination
We will not discriminate against you because you
exercise the rights granted to you by the CCPA. Unless otherwise specified in
the CCPA, we will not:
（1）
Refuse
to provide you with goods or services;
（2）
Charge
you different prices or fees for goods or services;
（3）
Provide
you with goods or services of different levels or quality; or
（4）
Take
other discriminatory measures.
However, if we provide some financial incentives permitted by the CCPA,
such incentives may result in different prices, discounts or quality levels.
Any incentive we offer will be reasonably related to the value of your personal
information to be collected. Where we offer these financial incentives, your participation is
optional. If you choose to participate, your participation will be subject to relevant
applicable terms, and you may withdraw at any time.
7. California
Shine the Light Law
We will not disclose your personal information to
third parties for their direct marketing of
products or services to you.