Privacy Policy

The “Privacy Policy” (“Policy”) is for [Beijing Zhengnian Beijia Technology Co., Ltd.] (“Company” or “We”) and users who use the services provided by the company and/or the company's Website and the APP (“Users” or “You”). This policy describes the related rights and responsibilities of the company and users.

Before accepting our services, please read carefully and thoroughly understand this policy (especially the content in bold or underline), and use the relevant services after confirming your full understanding of this policy. Once you start receiving services, it means that you have fully understood and accepted this policy.

 

Article 1 Policy Scope and Revision

1.1 This “Privacy Policy” is an integral part of the “User Agreement” and has the same legal effect as the “User Agreement”.

1.2 You understand and agree that the company has the right to unilaterally revise this policy according to the needs of business development and replace the pre-revised version with the revised version. Changes to this Privacy Policy are effective when they are posted on this page. Please pay attention to and understand the revision of this policy in time. If you disagree with the revised version, you should stop using the service immediately, otherwise you are deemed to agree and fully accept the revised version.

 

Article 2 Collection and Use of User Information

2.1 The personal information referred to in this policy refers to various information recorded electronically or in other ways that can identify the personal identity of the user's natural person alone or in combination with other information. The personal sensitive information mentioned in this policy refers to personal information that, once leaked, illegally provided or misused, may endanger personal and property safety, easily lead to personal reputation, physical and mental health damage or discriminatory treatment, etc., specifically including ID number, personal Biometric information, bank account numbers, property information, whereabouts and transaction information. Individual device information, log information, search keyword information, and other information or data that cannot be directly connected to a specific individual are not personal information or personal sensitive information.

 

2.2 You fully understand and agree that in order to optimize our services and ensure the necessary functions for security, you must authorize the company to collect and use your following information through the Website and the APP:

2.2.1 Information required for user registration

When you register as a user with your mobile phone number, we will verify whether your identity is valid by sending an SMS verification code. In the process of registering as a user, if you provide the following additional information to complete your personal information, it will help us provide you with better and more personalized services. The above additional information includes your avatar, nickname, gender, permanent residence, birthday. If you do not provide this additional information, it will not affect your access to our basic services.

2.2.2 Information required for display services

In order to provide you with page displays and search results that are more in line with your needs, we will collect information about the services you use and how you use them and associate this information, including:

(1) Device information: The company’s Website and the APP may read the device information you use when accessing or using the service, including but not limited to device type, device model, device settings, device identification code, operating system and application version, Language setting, resolution, software and hardware feature information.

(2) Log information: When you visit the company’s Website and the APP or use the service, the system may automatically receive and record the information on your device (including but not limited to IP address, search history, browsing history, browsing habits, Language, date and time of visit, telecom operator).

2.2.3 Information required for services and after-sales

(1) Order information

When you place an order to purchase a service, the system will generate an order for you to purchase the service. You need to fill in at least your username, user ID, and phone number in the order. The order will also include the order number, the service information you purchased, the time of order, the service fee and the payment method you used. You understand and agree that we will use your order information for your identity verification, service confirmation, payment settlement, order inquiries for you, and customer service consultation and after-sales service.

(2) Payment information

After you place an order, you can complete the payment through a third-party payment institution supported by the system. The payment function itself does not collect your personal information, but we need to include your order number, payment amount, and other payment institutions you choose. The transaction information is shared with the payment institution you choose to confirm your payment instruction and complete the payment.

(3) Information required for customer service and/or after-sales service

Our customer service and after-sales functions will use your account information and order information. To ensure the security of your account, our customer service will use your account information to verify your identity. When you need us to provide customer service or after-sales functions related to your order information, we will check your order information. Depending on the service content you requested, you may provide other information than the above information when communicating with our customer service staff to assist the customer service staff in completing the service you requested.

(4) Information required to ensure safety

In order to confirm the service status and provide you with after-sales and dispute resolution services, we must collect service-related information.

2.2.4 Information needed to optimize services

We may collect your order information, browsing history, and browsing habits for data analysis to describe user characteristics and use it to show you or recommend service information that interests you. In addition to the above information, we may also collect other information about you for reasonable needs to provide services or improve service quality, including information provided when you contact our customer service, and information sent to us when you participate in a survey. We may combine information from one service with information from other services in order to provide you with personalized content and recommendations. For the information collected from your various devices, we may associate them so that we can provide you with consistent services on these devices.

2.2.5 Information required to ensure account security

In order to improve the security of your use of the service and protect the security of your account, we may determine the risk of your account by understanding your order information, browsing history, browsing habits, commonly used software information, and equipment information.

2.3 The user can choose whether to authorize the collection and use of information

In order to provide you with more high-quality, satisfactory and personalized services and strive to improve your user experience, we may additionally collect and use your information. If you do not provide this information, you can still get the service provided to you, but you may not be able to get the user experience that this additional information brings to you.

2.3.1 Location information: We may collect your location information to determine where you are, and recommend services that can be purchased in your area (we only collect the geographic location where you are at the time, and will not contact and combine to determine your whereabouts).

2.3.2 Camera, photo album (picture library) information: You can upload photos or pictures to list and comment. If the company’s Website or the APP supports you to use facial recognition to log in or perform identity verification, we will collect your facial information.

2.3.3 You understand and agree that under the above circumstances, we may request to enable your geographic location (location information), camera, photo album (picture library) and other access permissions on your device to achieve these permissions, in order to complete the collection and use of the information involved. You can view the status of the above permissions item by item in your device and decide whether to turn on or off these permissions (if applicable). When you enable any permission, you authorize us to collect and use this information to achieve the corresponding goal. Once you close any authority, it means that you have cancelled the authorization. We will no longer continue to collect and use the personal information, and we will not be able to provide related services corresponding to the authorization for you. However, your decision to close your authority will not affect the collection, processing and use of information previously based on your authorization.

2.4 Exemption with authorization

You fully understand and agree that we do not need your authorization or consent to collect and use your personal information under the following circumstances, and we may not respond to your requests for correction/modification, deletion, cancellation, withdrawal of consent, and information request:

(1) Related to national security and national defense security;

(2) Related to public safety, public health, and major public interests;

(3) Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and execution of judgments;

(4) In order to protect your or other individuals' life, property and other major legal rights and interests, but it is difficult to obtain their consent;

(5) Your personal information disclosed to the public by yourself;

(6) Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

(7) Necessary for signing and performing related policies or other written documents with you;

(8) Necessary for maintaining the safe and stable operation of the provided services, such as discovering and handling service failures;

(9) Necessary for legal news reports;

(10) When it is necessary for academic research institutions to conduct statistical or academic research based on the public interest, and when providing academic research or description results to the outside, the personal information contained in the results is de-identified;

(11) Other circumstances stipulated by laws and regulations.

2.5 Information from third parties

2.5.1 You understand and agree that during your account registration and service use, you authorize the company's Website and the APP to obtain relevant information collected by related parties and partners.

2.5.2 If you use a third-party account to log in to the company’s Website and the APP, we can obtain the account information you have authorized to share from the third party, and bind your third-party account with your company’s Website and the APP account. So you can access to our services directly via the third-party account.

2.5.3 The information provided or shared by other users may contain your information.

2.6 Authorized use of information

In order to provide you with satisfactory and high-quality services, you understand, agree and authorize us to use your information for the following purposes:

(1) Provide you with various services, and maintain and improve these services.

(2) Recommend to you content that may be of interest to you, including but not limited to sending you service information, or showing you personalized third-party promotional information through the system, or cooperation with the company with your consent Partners share information so that they can send you information about their products and services. If you do not want to receive the above information, you can unsubscribe through the unsubscribe function;

(3) We may use your personal information to verify identity, prevent, detect, investigate fraud, endanger security, illegal, or violate policies, policies or rules with us or its affiliates to protect you, other users, or the legitimate rights and interests of us or its affiliates

(4) We may combine information from a certain service with information obtained from other services to provide you with more personalized service use.

(5) We will make statistics on the usage of our services and may share these statistics with the public or third parties to show the overall usage trend of our services. But these statistics do not contain any identifying information about you.

(6) Invite you to participate in surveys about our services.

(7) Other purposes approved or authorized by you or permitted by laws and regulations.

 

Article 3 Use of Cookies

3.1 You understand and agree that, in order to optimize your user experience, we may use various technologies to collect and store relevant information when you visit the company’s Website, the APP or access to our services, including the use of small data files to identify you, in order to understand your usage habits, to help you save the steps of re-entering registration information, or to help determine the security of your account. These data files may be cookies, Flash cookies, or other local storage provided by your associated application (collectively referred to as “cookies”).

3.2 You understand and agree that some of our services may only be realized through the use of cookies. You can modify your acceptance level of cookies or reject cookies, but in some cases, rejecting cookies may affect your safe access to the company's Website and the APP and use of services.

 

Article 4 Sharing, Transfer and Public Disclosure of User Information

4.1 Sharing of user information

4.1.1 Except for the following circumstances, we will not share your personal information with any individual, company or organization other than the company:

(1) Your explicit consent or authorization has been obtained in accordance with this policy or in advance;

(2) When necessary according to applicable laws, regulations, legal procedures, administrative or judicial mandatory requirements;

(3) To protect the company and its affiliates or partners, you or other company users, or the public interests, property or safety of the society from damage within the scope permitted by laws and regulations;

(4) To realize the core functions of our services or provide the services you need;

(5) Dealing with disputes or disputes between you and others according to your needs;

    (6) According to the policy signed with you or other legal documents;

(7) Use based on academic research;

(8) It is used based on the social public interest in compliance with laws and regulations.

4.1.2 You fully understand and agree that we may share your personal information with our affiliates. However, we will only share necessary personal information and are bound by the purpose stated in this policy. If we share your personal sensitive information or our affiliates want to change the purpose of using and processing personal information, we will ask for your authorization again.

4.1.3 You fully understand and agree that we may share you with partners (such as service providers, partners who entrust us to promote, communication service providers who send information on our behalf, payment institutions, etc.) or other third parties To ensure the smooth completion of the service provided to you. However, we will only share your information for legal, legitimate, necessary, specific and clear purposes, and only share personal information necessary to provide services.

4.1.4 You fully understand and agree that we may exchange user personal information with other companies or organizations under the circumstances of preventing fraud and other illegal activities and reducing credit risk, but this does not include violating the commitments made in this policy for profit Personal information for the purpose of selling, renting, sharing or disclosing in any other way.

4.2 Transfer of user information

Except for the following circumstances, we will not transfer your personal information to any individual, company or organization:

(1) Obtain your explicit consent or authorization in advance;

(2) When necessary according to applicable laws, regulations, legal procedures, administrative or judicial mandatory requirements;

(3) According to the policy signed with you or other legal documents;

(4) When it involves cooperation, joint operation, merger, acquisition, asset transfer or other similar transactions.

4.3 Public disclosure of user information

The company attaches great importance to the protection of your personal information. Without your consent, it will not be disclosed to unrelated third parties, and will not be made public, except for the following reasons:

(1) Obtain your explicit consent or based on your active choice;

(2) In cases where your personal information must be provided in accordance with the requirements of laws and regulations, mandatory administrative law enforcement or judicial requirements, we may publicly disclose your personal information based on the required personal information types and disclosure methods;

(3) Other circumstances that can be disclosed in accordance with legal provisions or policy between the parties.

You understand and agree that, in accordance with the law, sharing and transferring personal information that has been de-identified, and ensuring that the data recipient cannot restore and re-identify the subject of personal information is not an act of external sharing, transfer, and public disclosure of personal information. The storage and processing of such data will not need to notify you and obtain your consent.

 

Article 5 Protection of Users' Personal Information

5.1 Data security measures

We have used industry-standard security protection measures to protect the personal information you provide to prevent unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonable and feasible measures to protect your personal information.

5.2 We will take reasonable and feasible measures to avoid collecting irrelevant personal information. We will only retain your personal information for the period required to achieve the purpose stated in the policy, unless it is necessary to extend the retention period or as permitted or required by laws and regulations. If you cancel your account or we terminate the service or operation, we will delete or anonymize your personal information in accordance with Article 6.2.

5.3 As mentioned above, the company will use various security technologies, procedures and systems to prevent the loss, improper use, unauthorized reading or disclosure of users' personal information. However, you fully understand and agree: Due to technical limitations and various malicious methods that may exist, in the Internet industry, even if you do your best to strengthen security measures, it is impossible to always guarantee 100% security of information.

5.4 In the unfortunate event of a personal information security incident, we will inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and suggestions that you can independently prevent and reduce risks , Remedies for you, etc. We will inform you about the incident by letter, telephone, push notification, etc. If it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to make an announcement. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

 

Article 6 Preservation, Cross-border transmission, Deletion, Access and Management of Users’ Personal Information

6.1 Storage and cross-border transmission of user personal information

All your personal information will be stored in the territory of the People's Republic of China, except in the following circumstances:

(1) Laws and regulations clearly stipulate otherwise;

(2) Obtain your explicit authorization;

(3) In response to the above circumstances, we will protect your personal information in accordance with this policy and relevant laws and regulations.

6.2 Deletion of user personal information

6.2.1. You can apply to cancel your account on the company’s Website or the APP. After you successfully apply for cancellation of your account, we will complete the review of your account cancellation within 48 hours of your application. After the review is passed, we will delete or anonymize your personal information, as otherwise provided by laws and regulations except.

6.2.2 If we terminate the service or operation, we will notify you at least 30 days in advance, and delete or anonymize your personal information after terminating the service or operation.

6.3 Access to user personal information

You have the right to access your personal information in the following ways, except as otherwise provided by laws and regulations, or otherwise provided in this policy or the User Service Policy.

6.3.1 Account information.

6.3.2 Search for information.

6.3.3 Browse information.

6.3.4 Order information.

6.3.5 If you cannot access such information through the above-mentioned path, you can contact us through customer service. For other personal information generated during your use of our services, we will provide you with relevant arrangements in accordance with Article 6.6 “Respond to your above request”.

6.4 Correction and supplement of user's personal information When you find that your personal information is incorrect or needs to be supplemented, you can apply for correction or supplementation through the methods listed in “6.3 Access to User's Personal Information”.

   6.5 Deletion of User Personal Information

You can delete part of your personal information through the methods listed in “6.3 Access to User Personal Information”, except for those that should be kept as required by laws and regulations.

In the following situations, you can request us to delete personal information:

(1) Our handling of personal information violates laws and regulations;

(2) We collect and use your personal information without obtaining your explicit consent;

(3) Our handling of personal information has seriously violated our policy;

(4) You cancel your account and no longer use our services;

(5) We will never provide services to you again.

6.6 Responding to your above request To ensure safety, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request. We will reply within 30 days. If you are not satisfied, you can also initiate a complaint through customer service and the reporting phone [13301380137]. For your reasonable request, we do not charge a fee in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost as the case may be. We may reject requests that are unreasonably repeated, require excessive technical means (for example, the need to develop new systems or fundamentally change existing practices), bring risks to the legitimate rights and interests of others, or are very unrealistic.

6.7 You understand and agree that we will not be able to respond to your request in accordance with the requirements of laws and regulations in the following situations:

(1) Related to national security and national defense security;

(2) Related to public safety, public health, and major public interests;

(3) Related to criminal investigation, prosecution, trial, and execution of judgments;

(4) There is sufficient evidence to show that the subject of personal information has 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 commercial secrets.

Article 7 Protection of Minor Information

We attach great importance to the protection of the personal information of minors. In e-commerce activities, we presume that you have the corresponding capacity for civil conduct. If you are a minor under the age of 18, please read this policy carefully, and use our services or provide information to us with the consent of your guardian.

 

Article 8 Other

8.1 Independence of terms

If any clause in this policy or any part of any clause is found to be invalid, illegal or unenforceable in accordance with applicable laws, such invalidity, illegal or unenforceability will not affect any other clauses in this policy or the validity of any other parts of these terms.

8.2 Contact us

8.2.1 If you have any questions, comments or suggestions about this policy or your personal information-related matters, please contact customer service, or you can contact us by sending an email to [admin@mcredit.io].

8.2.2 Under normal circumstances, we will reply within 30 days. If you are not satisfied with our response, especially our personal information processing behavior has harmed your legal rights and interests, you can also seek a solution by filing a lawsuit with the court with jurisdiction in the defendant's domicile.

8.3 Effective date

This policy takes effect on [July 5th ] of [2019] .

8.4 Any disputes arising from or related to this policy shall be settled by the company through negotiation with you. If the negotiation fails, either party can bring a lawsuit to the people's court with jurisdiction where the company is located.