KALOS 隐私政策
Updated
Date: February 1, 2024
Effective Date: March 18, 2024
Welcome
to choose the products or services provided by Beijing Zhijian Software Co.,
Ltd. (hereinafter referred to as "we" or "Zhijian"). This
policy explains to you how we collect, use, store, and share your personal
information when you use our products or services, as well as the relevant
rights you enjoy.
If
you have any questions, comments, or suggestions, please contact us through the
following channel:
Email: product@zjinnova.com
This
policy will help you understand the following:
1. How
we collect and use your personal information
2. How
we use Cookies and similar technologies
3. How
we share, transfer, and publicly disclose your personal information
4. How
we protect your personal information
5. Your
rights
6. How
we handle the personal information of minors
7. How
your personal information is transferred globally
8. How
this privacy policy is updated
9. How
to contact us
Zhijian
deeply understands the importance of your personal information and will do our
best to protect its security and reliability. We are committed to maintaining
your trust in us and abide by the following principles to protect your personal
information: the principle of consistency between rights and responsibilities,
the principle of clear purpose, the principle of choice and consent, the
principle of minimum sufficiency, the principle of ensuring security, the
principle of subject participation, the principle of openness and transparency,
etc. At the same time, Zhijian promises that we will take corresponding
security protection measures in accordance with industry - mature security
standards to protect your personal information. Please read and understand this
"Privacy Policy" carefully before using our products (or services).
I. How We Collect and Use Your
Personal Information
(I) How We Collect Your
Information
We
will collect and use your personal information for the following purposes
described in this policy:
1. Provide
You with Products or Services
o
Information You Provide to Us:
When you use the "connect" function, you need to authorize us with
the "location" and "location information" permissions.
After you grant the authorization, we will obtain your precise location
information and longitude and latitude, and provide navigation services
according to the functions you need.
o
Information We Collect During Your
Use of the Service: We will collect information
about your use of products, services, and the way you use them, and associate
these pieces of information to improve our services. These include:
2. Provide
You with Security Protection
To prevent, detect, and investigate fraud, infringement, security hazards,
illegal acts, or acts that violate our agreements, policies, or rules, we may collect
or integrate your user information, service usage information, device
information, log information, and information obtained with your authorization
or shared in accordance with the law.
3. Other
Purposes
When we collect your information for other specific purposes not stated in this
policy, we will obtain your prior consent.
If we discontinue the operation of our products or services, we will stop
collecting your personal information. We will notify you of the discontinuation
of operation by individual delivery or public announcement, and delete or
anonymize the personal information we hold.
(II) How We Use Your Information
Collecting
your information is to provide you with services and improve service quality.
To achieve this goal, we will use your information for the following purposes:
1. Provide
you with the products or services you use, and maintain, improve, and optimize
these services and the service experience.
2. To
prevent, detect, and investigate fraud, infringement, security hazards, illegal
acts, or acts that violate our agreements, policies, or rules, and protect the
legitimate rights and interests of you, other users, the public, and us, we may
use or integrate your user information, service usage information, device information,
log information, and information we obtain with your authorization or shared in
accordance with the law to comprehensively detect and prevent security
incidents, and take necessary recording, auditing, analysis, and disposal
measures in accordance with the law.
3. Other
purposes permitted by you.
4.1 Basic Information: To complete the in - app purchase payment
process, we will collect your account information, such as the registered
mobile phone number and username, to identify your identity and ensure the
accurate attribution of transactions. At the same time, we will collect the
bank card number used for payment and the payment account name (such as
associated information of WeChat Pay, Alipay account, etc.). This information
is essential for completing the payment transaction. For example, when you
choose to pay by bank card for virtual props in a game APP, the system will
require you to enter the bank card number and other information. We only obtain
and use this information during the payment process to complete the payment.
4.2 Device Information: We collect your device model, operating
system version, and device unique identifier (such as Android ID, IDFA, etc.).
This information helps us ensure the safe and stable operation of the in - app
purchase payment service, identify device abnormalities, and prevent fraudulent
transactions. For example, through the device unique identifier, we can detect
whether an abnormal device is trying to make an in - app purchase on your
account, and take timely security measures to protect the security of your
account funds.
4.3 Transaction Information: We record the transaction amount,
transaction time, and transaction object (such as the name of the virtual
commodity purchased, service content, etc.) of each in - app purchase payment.
This information is used for transaction record queries, bill generation, and
subsequent possible after - sales dispute handling. For example, after you
purchase a commodity in a shopping APP, you can view these transaction information
at any time in the order record for easy verification and management.
4. Information
Use
5.1 Payment Processing: We use the collected payment - related
information to interact with payment institutions (such as banks, third - party
payment platforms) to complete your in - app purchase payment transaction. We
ensure that funds are transferred safely and accurately from your payment
account to the account of the APP developer or service provider, enabling the
purchase of goods or services.
5.2 Security Protection: We use device information and transaction
information for risk assessment and monitoring to identify and prevent security
risks such as payment fraud and card - skimming. For example, by analyzing
transaction behavior patterns (such as payment frequency, amount size, payment
location, etc.) and device login situations, we can determine whether there are
abnormal transactions. Once suspicious situations are found, we will take
timely measures, such as suspending the transaction and requiring you to conduct
additional identity verification, to protect your account and fund security.
5.3 Service Optimization: Based on the analysis of transaction
information and user behavior, we can understand your purchase preferences and
needs, so as to provide you with more personalized recommendation services,
optimize the display of in - app purchase goods or services, and enhance your
shopping experience. For example, if we find that you often buy a certain type
of game props, we may give priority to recommending relevant new props or
preferential activities to you in the future.
5. Information
Storage and Security
6.1 Storage: Your in - app purchase payment - related information
is stored on secure servers. We adopt strict data storage access control
measures to limit access to these data to authorized personnel only. The data
storage period is determined according to legal and regulatory requirements and
business necessity. After meeting the relevant requirements, we will securely
delete or anonymize the data that is no longer needed to reduce data storage
risks.
6.3 Security Measures: We use advanced encryption technology to
encrypt the personal information during transmission and storage to ensure that
the data is not stolen or tampered with during the transmission process. For
example, when you enter your bank card number for payment, the data will be
transmitted through an SSL - encrypted channel. At the same time, we establish
a complete security protection system, including firewall settings, intrusion
detection systems, etc., to resist external network attacks and protect your
information security. We regularly detect and repair security vulnerabilities
in the system and continuously improve security protection measures.
6. Information
Sharing
7.1 Third - Party Payment Institutions: To complete the payment
transaction, we will share necessary payment information (such as bank card
number, transaction amount, payment instructions, etc.) with the third - party
payment institution you choose. These institutions have professional security
protection capabilities and compliant operation experience in the payment
field. We sign strict data protection agreements with them, requiring them to
protect your information security in accordance with laws, regulations, and
industry standards. For example, when you choose Alipay for payment, we will
transfer the relevant payment information to Alipay, which will complete the
payment settlement process.
7.2 Service Providers: In some cases, we may share transaction -
related information with the providers of in - app purchase goods or services
to ensure that you can smoothly obtain the goods or services you purchase. For
example, after you purchase an online course, we may share your purchase record
and relevant information with the course provider so that it can provide you
with course learning services. However, the shared information is limited to
necessary transaction information, and we will require the service provider to
abide by strict confidentiality obligations. Without your explicit consent, we
will not share your personal information with other irrelevant third parties
for other purposes.
II. How We Use Cookies and Similar
Technologies
The
products or services we provide do not use Cookies and similar technologies.
III. How We Share, Transfer, and
Publicly Disclose Your Information
(I) Sharing
We
will not share your personal information with companies, organizations, and
individuals other than our service providers, except in the following cases:
1. Sharing
with Explicit Consent: After obtaining your explicit
consent, we will share your personal information with other parties.
2. Sharing
in Statutory Situations: We may share your personal
information externally in accordance with laws and regulations, for the
resolution of litigation disputes, or as required by administrative or judicial
organs in accordance with the law.
3. When
You Are Complained about for Infringing Intellectual Property Rights or Other
Legal Rights: We need to disclose your necessary
information to the complainant for complaint handling.
4. Sharing
with Authorized Partners: Only for the purposes stated in
this privacy policy, some of our services will be provided jointly by us and
authorized partners. We may share some of your personal information with
partners to provide better customer service and user experience. For
statistical analysis and other purposes, our products may integrate third -
party SDKs or other similar applications. For the security of your information,
we have signed strict data security and confidentiality agreements with third -
party SDK service providers. These companies will strictly abide by our data
privacy and security requirements. Unless we obtain your consent, we will not
share your personal identity information with them.
(II) Transfer
We
will not transfer your personal information to any company, organization, or
individual, except in the following cases:
1. Transfer
with Explicit Consent: After obtaining your explicit
consent, we will transfer your personal information to other parties.
2. In
Case of Merger, Acquisition, or Bankruptcy Liquidation:
When we experience mergers, acquisitions, or bankruptcy liquidation, or other
situations involving mergers, acquisitions, or bankruptcy liquidation, if
personal information transfer is involved, we will require the new company or
organization holding your personal information to continue to be bound by this
policy. Otherwise, we will require the company, organization, or individual to
re - obtain your authorization and consent.
(III) Public Disclosure
We
will only publicly disclose your personal information in the following cases:
1. After
obtaining your explicit consent;
2. If
we determine that you have violated laws and regulations or seriously violated
the relevant agreement rules of our service or product, or to protect the
personal and property safety of Zhijian or the public from infringement, we may
disclose your personal information in accordance with laws, regulations, or the
relevant agreement rules of our service or product after obtaining your
consent, including relevant violations and the measures Zhijian has taken
against you.
(IV) Exceptions to Prior
Authorization and Consent for Sharing, Transferring, and Publicly Disclosing
Personal Information
In
the following situations, sharing, transferring, and publicly disclosing your
personal information do not require prior authorization and consent from you:
1. Related
to national security and national defense security;
2. Related
to public security, public health, and major public interests;
3. Related
to criminal investigation, prosecution, trial, and judgment enforcement, etc.;
4. To
safeguard the major legitimate rights and interests of you or other individuals,
but it is difficult to obtain the consent of the person himself/herself;
5. Personal
information you have publicly disclosed to the public on your own;
6. Personal
information collected from legally publicly disclosed information, such as
legal news reports, government information disclosures, etc.;
7. Other
situations stipulated by laws and regulations.
According to legal regulations, sharing and transferring de - identified
personal information, and ensuring that the data recipient cannot restore and re
- identify the personal information subject does not belong to the external
sharing, transfer, and public disclosure of personal information. The storage
and processing of such data will not require separate notice to you and your
consent.
During the period when you use our
products and services, we will continuously retain your personal information.
If you cancel your account or actively delete the above - mentioned
information, we will retain your information in accordance with laws and
regulations such as the Cybersecurity Law. After you cancel your account or
actively delete the above - mentioned information, we will no longer use your
personal information for commercial purposes, but we may use your personal
information after anonymization.
Your personal information is
stored within the People's Republic of China. If some products or services
involve cross - border activities and we need to transfer your personal information
overseas, we will strictly comply with the provisions of laws and regulations
and ensure the security of your personal information.
1.
We will take various preventive measures to protect your personal
information from unauthorized access, public disclosure, use, modification,
damage, or loss. We will use encryption technology to ensure data
confidentiality; we will use trusted protection mechanisms to prevent data from
being maliciously attacked; we will deploy access control mechanisms to ensure
that only authorized personnel can access personal information. We will also
enhance employees' awareness of the importance of protecting personal
information.
2.
We will take reasonable and feasible measures to avoid collecting
irrelevant personal information as much as possible. We will only retain your
personal information for the period required to achieve the purposes described
in this policy, unless an extension of the retention period is required or
permitted by law.
3.
The Internet environment is not 100% secure. Although we have these
security measures, please note that there is no "perfect security
measure" on the Internet. We will do our best to ensure the security of
your information.
4.
The Internet is not an absolutely secure environment, and email and
instant messaging are not encrypted. We strongly recommend that you do not send
personal information through such means. Please use a complex password to help
us ensure the security of your account.
5.
In the event of a personal information security incident, we will,
in accordance with the requirements of laws and regulations, promptly inform
you of the basic situation and possible impacts of the security incident, the
disposal measures we have taken or will take, the suggestions for you to
independently prevent and reduce risks, and the remedies for you. We will
promptly inform you of the relevant situation of the incident through means
such as emails, letters, phone calls, and push notifications. When it is
difficult to inform individual personal information subjects one by one, we
will take reasonable and effective ways to issue public announcements.
At the same time, we will also take the initiative to report the handling
situation of personal information security incidents in accordance with the
requirements of regulatory authorities.
In accordance with relevant
Chinese laws, regulations, standards, and the common practices of other
countries and regions, we guarantee that you can exercise the following rights
over your personal information:
You have the right to access your
personal information, except in cases otherwise stipulated by laws and
regulations.
When you find that the personal
information we process about you is incorrect, you have the right to request us
to make corrections. You can notify us by phone or email. We will reply to your
correction request within 30 days. To ensure security, we will verify your identity
information before you exercise the right to correct information.
In the following situations, you
can request us to delete your personal information:
1.
If our processing of personal information violates laws and
regulations;
2.
If we collect and use your personal information without your
consent;
3.
If our processing of personal information violates our agreement
with you;
4.
If you no longer use our products or services, or if you cancel
your account;
5.
If we no longer provide products or services to you.
If we decide to respond to your deletion request, we will also notify the
entities that have obtained your personal information from us to delete it in a
timely manner, unless otherwise stipulated by laws and regulations or these
entities have obtained your independent authorization.
When you delete information from our services, we may not immediately delete
the corresponding information in the backup system or anonymize these pieces of
information.
Each business function requires
some basic personal information to be completed. For the collection and use of
additional personal information, you can give or withdraw your authorized
consent at any time.
When you withdraw your consent, we will no longer process the corresponding
personal information. However, your decision to withdraw consent will not
affect the personal information processing carried out based on your previous
authorization.
In some business functions, we may
make decisions based solely on non - human automated decision - making
mechanisms such as information systems and algorithms. If these decisions
significantly affect your legitimate rights and interests, you have the right
to request an explanation from us, and we will also provide appropriate
remedies.
To ensure security, you may need
to submit a written request or prove your identity in other ways. We may first
require you to verify your identity and then process your request. We will
reply within thirty days.
In principle, we do not charge for your reasonable requests. However, for
requests that are repeatedly made multiple times and exceed a reasonable limit,
we will charge an appropriate cost. For requests that are unreasonably
repetitive, require excessive technical means (such as the need to develop a
new system or fundamentally change the current practices), pose risks to the
legitimate rights and interests of others, or are extremely impractical (such
as involving information stored on backup tapes), we may reject them.
In the following situations, in accordance with the requirements of laws and
regulations, we will not be able to respond to your requests:
1.
Directly related to national security and national defense
security;
2.
Directly related to public security, public health, and major
public interests;
3.
Directly related to criminal investigation, prosecution, trial, and
judgment enforcement, etc.;
4.
There is sufficient evidence to show that you have subjective
malice or abuse of rights;
5.
Responding to your request will cause serious damage to the
legitimate rights and interests of you or other individuals or organizations;
6.
Involving trade secrets.
Our products, websites, and
services are mainly aimed at adults. Minors are not allowed to create their own
user accounts without the consent of their parents or guardians.
Although the definitions of minors vary according to local laws and customs, we
consider anyone under the age of 18 as a minor.
If we find that we have collected the personal information of minors without
prior verifiable parental consent, we will try to delete the relevant data as
soon as possible.
VII. How Your
Personal Information is Transferred Globally
In
principle, the personal information we collect and generate within the People's
Republic of China will be stored within the People's Republic of China.
Since
we provide products or services through resources and servers 遍布全球，this means that, after obtaining your authorized consent, your
personal information may be transferred to overseas jurisdictions where you use
the products or services, or accessed from these jurisdictions.
Such
jurisdictions may have different data protection laws, or even no relevant
laws. In such cases, we will ensure that your personal information is protected
to a level equivalent to that within the People's Republic of China. For
example, we will request your consent for cross - border personal information
transfer, or implement security measures such as data de - identification
before cross - border data transfer.
VIII. How This Policy is Updated
Our
privacy policy may be changed.
Without your explicit consent, we will not reduce the rights you enjoy under
this privacy policy. We will publish any changes made to this policy on this
page.
For major changes, we will also provide more prominent notifications
(including, for some services, sending notifications via email to explain the
specific changes to the privacy policy).
The major changes referred to in this policy include, but are not limited to:
1. Significant
changes occur in our service model. For example, changes in the purpose of
processing personal information, the types of personal information processed,
and the way of using personal information, etc.;
2. Significant
changes occur in our ownership structure, organizational structure, etc. For
example, changes in ownership caused by business adjustments, bankruptcies,
mergers, acquisitions, etc.;
3. The
main objects of personal information sharing, transfer, or public disclosure
change;
4. Significant
changes occur in your rights to participate in personal information processing
and the way to exercise these rights;
5. Changes
occur in the responsible department for handling personal information security,
contact methods, and complaint channels;
6. A
personal information security impact assessment report indicates high risks.
IX. How to Contact Us
If
you have any questions, comments, or suggestions regarding this privacy policy,
please contact us through the following method:
Email: product@zjinnova.com
Generally, we will reply within thirty days.