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:

·   Microsoft Internet Explorer

·   Microsoft Edge

·   Mozilla Firefox

·   Google Chrome

·   Safari for macOS

·   Safari for iOS

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.