Updated on: June 30, 2020
Effective date: June 30, 2020
Before using our products or services, providing your personal information to us or allowing us to collect your personal information, please read this Policy carefully to understand our practices regarding your personal information, and please access it frequently to understand the updates to this Policy. If you have any questions, please let us know.
I. How We Collect and Use Your Personal Information
"Personal information" refers to all the data that can directly or indirectly identify or relate to a natural person by reference to the natural person's identification, attributes, characteristics or other identities, or through a combination of these identities. You may need to provide personal information when you use CARLCARE products or services. You are not required to provide your personal information to CARLCARE, but in some cases, if you choose not to do so, we will not be able to provide you with related products or services, nor will we be able to respond or resolve the problems you've encountered. We will collect and use your personal information only for the purposes described in this Policy. The following are some examples of personal information that we collect about you:
1.Personal information we collect
1.1 Information you provide directly to us
In order to enable you to access our product functionalities and services, we may ask you to provide necessary information when we provide products or services to you. For example:
- Account information. When you register for CARLCARE products or services, such as creating an APP account, participating in forum community interactions, etc., depending on the functionalities of different products or services, you may need to provide: a phone number, name, nickname, avatar, birthday, nationality, age, the city where you are located and other information; when you need to log in to the relevant system more conveniently, such as using face recognition or fingerprint unlocking for quick login, you may need to provide the corresponding facial or fingerprint biometrics;
- Order information. When you purchase our products or services online or offline, in order to ensure that the products or services can be provided to you in a timely and accurate manner, we may ask you to provide information such as the recipient's name, phone number, zip code and address;
- After-sales information. When you need us to provide after-sales service or hope that we solve the problems you encountered in using the products or services, you may need to provide information such as your name, phone number, device information, residential address, problem descriptions in scenarios such as filling out the warranty card / electronic warranty card or giving feedback on the problem;
- Other information you provide to us. For example, when you participate in our activities such as a sweepstakes, prize quiz and fan trial research, you may need to provide a personal nickname, avatar, name, phone number and other information according to the needs of specific scenarios.
1.2 Information we obtain during your use of our products or services
During your use of CARLCARE products or services, as needed to provide you with products or services, with your authorization or consent, we will collect the necessary information, including:
- Device information. Given that certain services will be for a particular type of device, in the process of activating a business and using the device, we may collect device-related information such as the device name, device model, region and language settings, device identification code, device hardware information and status, user habits, IP address, Mac address, operating system version, PLMN, Android system version, network operator equipment, etc.
- Log information. When you use our products or services, we may collect certain information and store it in log files. For example, service access time, access frequencies, usage time, temporary historical messages, standard system logs, event information (errors, crashes, restarts, upgrades), etc.
- Location information. When you need to use certain location-based services, such as using navigation software, viewing the weather conditions in a geographic location, retrieving your phone's location, sharing your geographic location with others, etc., with your consent, we may collect and process approximate or precise information about the actual location of the equipment you use. For example: latitude and longitude information, country or area code, city code, community identifier, navigation route, operator identifier, etc. Surely, unless you provide consent or in order to comply with a legal requirement by the relevant country or region, we will not continue to collect your location information to identify your whereabouts. You have the right to turn off location service permissions for related apps directly on your mobile device.
- Cookie information. Our websites, interactive applications, CARLCARE products and advertisements may use technologies such as cookies, pixel tags and web beacons to collect and store your relevant personal information.
1.3 Information obtained from third parties
Where permitted by law, we may obtain your personal information from public channels or other third parties. For example: when you use third-party social networking services or pre-installed third-party applications, we may also obtain your personal information from these services or applications. In addition, we will explain it to you at the time of collection and obtain your consent.
CARLCARE may also use other methods to collect other information about you, your device or the use of services, which will be explained to you at the time of collection or we will obtain your consent.
1.4 Collection and use of non-personal information
Non-personal information refers to information that cannot be used to determine the identity of a natural person, such as website visits, application downloads, product sales and various statistical summary information. The purpose of our collection is to understand how users use our products and services, and we use this as a basis to continuously improve our services and better meet user needs. Since this type of information is not personal information, we may collect, use, disclose and transfer non-personal information at our discretion as permitted by law; when this type of information is combined with personal information, it will be treated as personal information. We will process such information in accordance with the requirements of relevant laws and regulations on personal privacy data protection.
2.Purpose of our use of personal information
2.1 To provide you with registration services and account management services. We will use the basic information you filled out during registration to provide you with the corresponding registration services and subsequent account management services;
2.2 To provide customer support and related services for your purchase and post-purchase activities. For example: your provision of necessary information may be involved when we offer delivery services, warranty services, technical support, or via feedback of error reports to quickly locate and fix existing abnormal issues, etc.
2.3 To provide you with information services for your needs or interests. For example: we or a third party may use your location information to provide you with weather forecast push, geographic location navigation and other related information services; we may use your personal information, analyze your usage habits and behavior preferences, and provide you with notification or content push services based on your consent.
2.4 To continue to provide you with better products and services, we may invite you to participate in our product improvement and user experience related programs or interactive activities. After you join our programs or activities, we may collect your necessary personal information such as mobile phone numbers (mainly used for research and return visits), device information, operation behavior data, location information and log information for statistical analysis, so as to continuously improve and optimize products and provide a better user experience;
2.5 For commercial promotion activities. If you enter into a sweepstake, contest, or similar promotion, we may use the information you provide to administer those programs;
2.6 We may conduct macro customer surveys to analyze market share. We may collect information such as website visits, application downloads and product sales to analyze market share and provide a reference for business development.
You can clear all cookies stored in websites and applications, but if you do so, you will need to change the settings every time you visit our websites or applications. Most browsers have a function to block cookies. If you want to manage cookies through a browser, you can refer to the browser developer’s introduction or search on the Internet. Please note that if cookies are blocked, certain website features and functionalities may not function properly or may even stop functioning completely.
III. How We Store and ProtectYour Personal Information
The personal information collected based on your consent will be stored in accordance with the laws and regulations on personal privacy data protection of the countries concerned. To the extent not prohibited by local laws and regulations, we may also store the collected personal information in countries or regions outside the country where the business is located.
Whether we store personal information in the country where the business is located, or in other countries or regions to the extent that doing so does not violate laws and regulations, we will retain it in accordance with the relevant laws and regulations on data storage. At the same time, we will consider the characteristics, scope and purpose of personal information processing, the risks that may be encountered in the processing, and the serious consequences caused by the damage, etc., and implement the necessary security measures. For example: we will use encryption and de-identification methods to store the collected personal information. We will also keep the information for the shortest storage period specified by law. For those not specified by law, we will retain the information according to the shortest storage period required for business. For data that exceeds the storage period, or data that you request us to delete, we will delete said data accordingly or take other appropriate measures without violating the relevant laws and regulations. In addition, we will take other necessary measures to protect the security of your personal information and prevent data from being misused, unauthorized access, and unauthorized modification, disclosure or destruction, etc.
Nevertheless, we need to remind you that no matter how perfect the measures are, there is no absolute guarantee of avoiding the occurrence of data storage security incidents. If a security breach occurs, we will report it to the corresponding regulatory authorities as required by the relevant laws and regulations, and provide the type of personal data involved in the breach, the number of data subjects, the possible consequences of the breach, and the remedial measures we intend to take according to the requirements of the regulatory authorities. We will take the best possible measures to remedy or mitigate the damage and consequences of data leakage. When permitted or required by laws and regulations, we will inform you of the possible consequences or significant damage to you in a timely manner, so that you can take appropriate measures promptly to protect your rights as much as possible.
There is no absolutely safe website, Internet transmission, computer system and wireless connections. Except the necessary protective measures we have taken, users have to strengthen the awareness of privacy security risks. For example, when you jump from our services to third-party websites, links, products or services, for the security of any data collected by those websites, links, products or services, please read through the terms and conditions of those third parties carefully. We do not assume any legal responsibility for data security issues caused by such third parties. If you find that certain contents, advertisements or functions in our websites, products or services may be provided by a third party and may possibly endanger your privacy and security, please contact us promptly, as we will handle it with priority in accordance with laws and regulations.
IV. How We Share, Transfer and Disclose Your Personal Information and Data
In sharing, transferring, and disclosing your personal information, we uphold the principles and requirements of minimization, necessity, and legality. Under normal circumstances, we do not share, transfer or disclose your personal information externally. However, to the extent permitted by applicable laws and regulations, we may share, transfer and disclose your personal information in the following situations:
We may share the necessary personal information with authorized third-party partners (including logistics service providers, data storage service providers, after-sales service providers, marketing promotion service providers, etc.) for the performance of certain functions or to provide you with better service and a better user experience. For example: when you purchase CARLCARE products, CARLCARE may need to provide your relevant personal information to the logistics service provider to arrange delivery; when providing you with after-sales service, we may need to provide your relevant personal information to the after-sales service provider in order to offer better service and support. We uphold the principles of minimization, necessity, and legality to carry out such sharing. Before sharing information, we will sign strict confidentiality agreements with authorized partners and require them to take relevant confidentiality and security measures to process personal information in accordance with this Policy and applicable laws in your jurisdiction.
In order to provide evaluation, analysis or other business services, we may also share your non-personal information with third parties, for example: we may use aggregated data to help partners (such as advertising service providers) understand the effectiveness, feedback and usage trends of their services.
We will only publicly disclose your personal information in the following circumstances: with your explicit consent; or to enforce or assist in the enforcement of a mandatory disclosure requirement by law.
V. How Your Personal Information is Transferred Across Borders
As a globally operating company, we have resources or servers in different countries or regions worldwide to support our products and services. In order to better provide services to you, to the extent permitted by local laws and regulations and with your authorized consent, we may transfer your personal information to a third country or region for storage or processing, or your data may be accessed by a third country or region. The privacy protection laws of these countries or regions may be different. We will follow the legal requirements of the country or region where the personal information is located to carry out the corresponding cross-border transfer and other processing of personal information.
VI. Your Rights to Your Personal Information
As a data subject, you have a series of rights to your personal information, including the right to confirm, access, correct, delete, withdraw consent, and lodge complaints. We fully understand and respect your rights. We will also take active steps to ensure that your rights are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we do not charge a fee for your lawful and reasonable request, but we will charge a certain fee for repeated requests that exceed the reasonable limit where applicable. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, to develop new systems or fundamentally change existing practices), pose risks to the legal rights of others or are very unrealistic, or violate the mandatory provisions by law.
6.4 Right to complain: You have the right to lodge a complaint by sending us an email at email@example.com. We will respond promptly after receiving your complaint. If you are unsatisfied with our response, especially if our processing of personal information damages your legitimate rights and interests, you may refer your complaint or report to your local statutory personal data protection department, or file a lawsuit with a competent court.
VII. How We Handle the Personal Information of Children
Children (laws of different countries or regions have their own threshold when defining the age of children, we will define children mainly based on the laws and regulations of the country or region where the business is located) are not allowed to use our products or services unless with the consent and guidance of their legal guardians and permitted by relevant laws and regulations. In principle, we do not actively collect the personal data of children. We will only collect, use and disclose a child's personal information with the explicit permission and consent of the child's guardian, to the extent permitted by law, and when it is absolutely necessary to collect such information. If at any time the guardian needs to access, modify or delete the personal information related to the child under guardianship, please contact us by methods as described herein, and we will respond in a timely manner. If you find that a child’s information has been passed to us without the awareness of the legal guardian, please send an email to firstname.lastname@example.org to contact us. We will remove the relevant information as soon as possible. If we find that we have collected the personal information of a child without the prior consent of a verifiable guardian, we will also take steps to remove the relevant content as soon as possible.
VIII. Third-Party Service Providers and Services
IX. Supplement and Update of the Policy
The content of TRANSSION products or services described herein may vary according to the type of product you use, system version, or requirements of local laws and regulations.
X. How to Contact Us
Address: 17th Floor, Desay Building, No.9789 Shen Nan Road, Hi-Tech Park, Nanshan District, Shenzhen, China