[IMPORTANT] Please read carefully (minors should be accompanied by their guardians) and understand this Policy (especially the contents in bold) before using Sunseeker Services. You shall be sure that you have fully understood and agreed to this Policy before using the services. If you do not agree to this Policy, it may result in the failure of Sunseeker Services to function properly or to achieve their intended purposes, and you shall immediately stop accessing/using Sunseeker Services.
This Policy will help you understand the following:
I. How We Collect and Use Personal Information
III. How We Store and Protect Personal Information
IV. How to Manage Your Personal Information
V. Third-Party Services
VI. Protection of Minors
VII. Notices and Amendments
VIII. How to Contact Us
I. How We Collect and Use Personal Information
We collect your personal information primarily to make it easier and more satisfying for you and other users to use Sunseeker Services. This information helps us achieve this goal.
(I) We will collect and obtain your personal information through the following ways:
1. Information you provide. For example: Information you provide to us when you register for a Sunseeker service account or make a purchase of a product or Sunseeker Services;
2. Information we obtain about you. Information we collect, summarize and record when you use Sunseeker Services, including log, location and device information.
(II) We collect and use the following types of personal information for the following purposes.
You understand and agree that we hope to provide perfect products and services. Therefore, we will continue to improve our products and services, which means that with their iteration, expansion and upgrade, we may often launch new services or business functions, or re-arrange business functions, and may require the collection of new personal information or change the purpose or method of using personal information. Please note that if we use your personal information for other purposes not described in this Policy, or if we collect additional personal information not mentioned here, we will obtain your consent through page prompts, interactive communications, website announcements or other means. Once we have obtained your consent, such additional uses will be deemed part of this Policy, and this Policy shall also apply to such additional information. Learn more about the specific use of your personal information. If you have any questions in this process, you may contact us through the feedback channels listed in the “How to Contact Us” section of this Policy and we will respond as soon as possible.
1. Help you complete the registration and login
To experience richer and more complete Sunseeker Services, you can register and log in to your Sunseeker service account. You need to provide basic registration or login information, including email address and verification code match results (sensitive personal information), and create your account number, username and password.
During the registration, if you provide the following additional information, it will help us provide you with personalized recommendations and a better service experience. If you do not provide this information, your use of the basic functions of Sunseeker Services will not be affected. Meanwhile, we also provide the function for cancelling a registered account. If the conditions stipulated in the service agreement and the relevant national laws and regulations are met, you can cancel the account on the “Delete Account” page. You can follow the prompts in your personal settings to cancel your account.
After the cancellation of your Sunseeker service account, we will stop providing you with Sunseeker Services and delete your personal information or anonymize it as per your request, unless otherwise stipulated by laws and regulations.
2. Maintain the normal operation of basic functions. While using our services, in order to identify the abnormal status of accounts, understand product adaptability, provide basic services such as browsing and searching, ensure the normal operation of services, and optimize the service experience, we may directly or indirectly collect, store and link information about the services you use and how you use them, including:
(1) Log information: When you use our services, we may automatically collect (including during background running) your detailed usage information and store it as a network log, including your login account number, search query contents, IP address, browser type, telecom operator, network environment, language used, date and time of visit, web browsing history, Push open record, length of stay, refresh record, posting record, favorites and sharing.
(2) Device information: Based on the specific permissions you have granted when installing and using the software, we may receive and record (including during background running) information about the device you are using. Such as device model, device log, operating system and version, client version, device resolution, package name, device settings, device identifier (MAC address/IMEI/Android ID/Open UDID/GUID/MAC/OAID/IDFA/SIM card IMSI information), hardware and software characteristics information, and information about the location of the device (such as IP address, GPS location information). In order to collect these personal device information, we will request access to your device, including device information permissions, location permissions, etc. Please note that it cannot identify a specific natural person with separate device and log information. If we use the above information in combination with other personal information to identify a specific natural person or in combination with information that can identify a natural person, we will anonymize and de-identify such personal information when using such information, unless we obtain your authorization or otherwise required by laws and regulations. Such information shall be processed and protected in accordance with this Policy during its use.
3. Scan QR code/AR scan/take photos and related editing functions. When you use the function of scan QR code/AR scan/take photos, we need you to grant us access to your camera and storage space of your device, and collect the uploaded picture information you provide after scan QR code/take photos. Your photos may contain sensitive personal information, so please be careful when you are requested to provide them.
8. Language interaction function
When you use the voice interaction feature, we need you to grant us access to your microphone/recording, and may collect your voice interaction information and recorded voice. If you click to report inaccurate recognition when using voice interaction recognition service, we need to collect your audio to optimize the service. Your voiceprint is sensitive personal information, so please be careful when you are requested to provide it. If you use the features associated with video recording, you also need to grant us access to camera and storage permissions on your device, and collect the uploaded video information you provide after video recording. The videos you provide may contain sensitive personal information, so please be careful when you are requested to provide them.
4. Information release function. When you use the information release function in Sunseeker Services, we need to collect your mobile phone number and verification code match results (sensitive personal information) according to applicable laws and regulations. In addition, we may need to collect corresponding personal information and obtain appropriate permissions based on your posting behavior and the type of content you post. For instance, when you post images or videos at the Cloud Village-Plaza, we need your permission to access your camera and/or photo and storage space, and to collect the image or video information (which may contain sensitive personal information) that you need to post. If you need to post your location when posting images or videos, we may need you to grant us access to your location data and collect your location information (sensitive personal information). Please note that if the information you post contains the personal information of other people, you shall obtain their consent before posting.
5. Sharing and activity participation. When you share or receive shared information, or participate in activities, we need to access your clipboard and read the passwords and links contained in it to realize functions or services such as jumping and sharing.
6. Product purchase and payment function. In order to facilitate the delivery of goods or services to you, you shall at least provide us with the personally identifiable information of the receiver, name, shipping address, postal code, receiver, contact number and payment status information as prompted. If you refuse to provide such information, we will not be able to complete relevant delivery services. If you order goods or services for someone else through Sunseeker Services, you need to provide the above information of the actual purchaser. Before providing us with such information of the actual purchaser, you need to ensure that you have obtained its authorization and consent. In case of payment settlements during our services, you can choose payment services provided by our related parties or third-party payment institutions that cooperate with us. During payment services, we may need to share information such as your Sunseeker service order number and transaction amount with the payment institutions so that they can confirm your payment instructions and complete the payment. In order to display the order information of your account and protect your after-sales interests, we will collect order information, transaction and consumption records, virtual property information (sensitive personal information) generated during your use of Sunseeker Services to show you such information and manage your order. In case of a transaction refund, we may ask you to provide your bank account information, including card information and third-party account information (sensitive personal information) to process the refund request. When you contact us, we may keep your communication/call records and content or the contact information and related information (sensitive personal information) you leave in order to contact you or help you resolve relevant issues or to record the solution and outcome. In order to confirm the status of the transaction and provide you with after-sales and dispute resolution services, we will collect your transaction, payment and logistics information related to the transaction progress through the transaction object, payment institution and logistics company selected by you based on the transaction, and share your transaction, payment and logistics information with the relevant service providers mentioned above.
7. Bluetooth/Siri-based services. When you need to use Bluetooth to connect to a smart device, you need to turn on the Bluetooth permission. If you need to control and use Sunseeker Services through Siri, you need to turn on Siri and search permissions.
8. Message notification. For your contact details (such as contact email and phone number) you provide during the use of the services, we may send multiple types of notifications to one or more of them during operation, which are used for user message notification, identity verification, security verification and user experience research. In addition, we may also send you commercial information about services, features or activities that may be of interest to you by email, SMS or phone. If you do not wish to accept this information, you can unsubscribe via the method provided in the SMS.
9. Provide you with customer service or other user response functions. When you contact our customer service or use other user response functions (such as making in-sales and after-sales applications, personal information protection complaints or suggestions, other customer complaints and needs), we may require you to provide the necessary personal information to match and verify your user identity to protect your account and system security. We may also keep your contact information (the contact information that you use to contact us or other contact details that you provide), records of your communication/calls with us, your feedback in the platform response function (including text/pictures/audio/video/call records), and other necessary information related to your needs in order to contact you or assist you in solving problems, or to record the resolution and outcome of relevant issues.
10. Provide you with security. In order to improve the security of your use of the services provided by us and our partners, protect the personal and property safety of you or other users or the public, better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks and network intrusions, and more accurately identify the violation of laws and regulations or relevant agreement rules of Sunseeker Services, we may collect, use or integrate your account, transaction, device and log information, as well as information shared by our affiliates and partners with your authorization or in accordance with the law, so as to comprehensively judge your account and transaction risks, perform identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis and disposal measures in accordance with the law.
11. Improve our services. We may invite you to participate in surveys about Sunseeker Services to help us improve existing services or design new services; in addition, we may use your information for software updates.
12. Exceptions to authorization and consent. According to relevant laws and regulations, your authorization and consent are not required to collect your information in the following circumstances:
(1) It is related to the performance of obligations stipulated by laws and regulations;
(2) It is directly related to national and defense security;
(3) It is directly related to public safety, public health and major public interest;
(4) It is directly related to criminal investigation, prosecution, trial and judgment enforcement;
(5) It is to safeguard the significant legitimate rights and interests of life and property of yours and other individuals, and it is difficult to obtain your consent;
(6) The personal information collected is disclosed by you to the public;
(7) The personal information is collected from legally and publicly disclosed information, such as legal news reports and public government information;
(8) It is necessary for the signing and performance of contracts in accordance with your requirements;
(9) It is necessary for legitimate news reports; and
(10) Other situations stipulated by laws and regulations.
13. Tips for specific function permissions. If you need to turn off the function permissions that you have turned on to use some of the above specific functions (including camera, photo, microphone, address book, storage, device information, geographic location and calendar permission), most mobile devices will support it. For specific methods, please refer to or contact the service provider or manufacturer of your mobile device. Please note that by turning on any permission, you authorize us to collect and use relevant information to provide you with the corresponding services. Once you turn off any permission, you cancel the authorization, and we will no longer collect and use relevant information based on the permission, nor shall we be able to provide you with the services corresponding to that permission. However, your decision to turn off permissions shall not affect previous collection and use of information based on your authorization.
14. Tips for sensitive personal information. Sensitive personal information refers to personal information that, once leaked or illegally used, is likely to cause damage to the personal dignity of natural persons or endanger personal and property safety. The information provided by you or collected by us may contain sensitive personal information about you, such as identification number, personal biometric information (including facial identification characteristics, voiceprint), bank account numbers, address books and friend lists, communication records and content, property information (including virtual property information such as virtual currency and transactions), travel and location information, web browsing records, and transaction information. Please be careful and be mindful of sensitive personal information.
We or our partners may obtain and use your information through Cookies or similar technologies and store such information as log information. By using Cookies, we provide users with an easy and personalized web experience. Cookies are text files with small pieces of data that are sent to your browser from a web server and stored on your computer’s hard drive. Cookies are used to benefit the users. For example, to make the login process of Sunseeker Services faster, you can choose to store your username in a Cookie. This shall make it easier and faster when you log into Sunseeker Services next time. Cookies help us identify the pages and content you connect to, the time you spend on Sunseeker Services and the Sunseeker service pages you select. Cookies enable us to serve you better and faster, and personalize your experience with Sunseeker Services. However, you shall be able to control if and how Cookies are accepted by your browser. Please check the files that come with your browser for more relevant information. We and third-party partners may collect, use and store your information through Cookies or similar technologies. We may use our own Cookies or similar technologies for the following purposes:
(1) Remember your identity. For example: Cookies or similar technology helps us identify you as our registered user or save your preferences or other information about you that you provide to us;
III. How We Store and Protect Personal Information
(I) Storage of personal information. Unless otherwise stipulated by laws and regulations or regulatory authorities, we will only retain your information for the shortest period necessary for the purposes described in this Policy. If we terminate the services or operations, we will promptly stop continuing to collect your personal information, notify you in advance based on relevant laws and regulations, and delete or anonymize your personal information after the termination of the services or operations, unless otherwise stipulated by laws and regulations or regulatory authorities.
(II) Protection of personal information. We take personal information security very seriously, and shall take all reasonable and practicable measures to protect your information.
1. Technical measures for data security. We will adopt security protection measures in line with industry standards, including establishing reasonable system specifications and security technologies to prevent your information from being accessed, used and modified without authorization, so as to avoid data damage or loss. Various encryption techniques are adopted in web services. For example, in some services, we will use encryption technology (such as SSL) to protect your information, adopt encryption technology to encrypt and store it, and isolate it through isolation technology. When information is used, such as information presentation and information correlation calculations, we use a variety of data desensitization techniques to enhance the security of information in use. We adopt strict data access control and multi-factor authentication technology to protect information and prevent data from being used illegally.
2. Other security measures we take to protect information. We manage and regulate the storage and use of information by establishing a data classification and grading system, data security management specifications and data security development specifications. We maintain comprehensive security controls over data through information contact confidentiality agreements, monitoring and auditing mechanisms. We increase security awareness.
3. We only allow employees and partners who need to know your information to access it, and we have set up strict access control and monitoring mechanisms for this purpose. We also require all persons who may have access to your information to comply with appropriate confidentiality obligations. If they fail to fulfill these obligations, they may be subject to legal responsibility or be suspended from the partnership with Sunseeker Services.
4. The Internet is not an absolutely secure environment. We recommend that you use complex passwords when using such tools, and take care to protect your information security.
5. Security incident handling. When communicating with a third party or purchasing goods and receiving services through Sunseeker Services, you shall inevitably disclose your information, such as contact information or postal address, to the counterparty or potential counterparty. Please properly protect your information and only provide it to others when necessary. In response to possible risks such as personal information leakage, destruction and loss, we have developed a number of systems to clarify the classification standards of security incidents and vulnerabilities as well as corresponding handling procedures. We have also established a special emergency response strategy for security incidents. In accordance with the requirements of the security incident handling specification, we will initiate security plans for different security incidents, carry out stop loss, analysis, positioning and formulation of remedial measures, and conduct joint tracing and strike with relevant departments. In the event of an information security incident, in accordance with the requirements of laws and regulations, we will promptly notify you of: the basic situation and possible impact of the security incident, disposition measures we have taken or will take, our suggestions to prevent and mitigate risks by yourself, remedies for you, etc. Meanwhile, we will promptly inform you of the situation related to the incident by means such as email, letter, telephone and push notification. When it is difficult to inform the information subjects one by one, we will make announcements in a reasonable and effective manner. In addition, we will proactively report the disposition of information security incidents as required by regulatory authorities. Please understand that due to the limitations of technology and risk prevention, even if we have tried to strengthen security measures, we cannot always guarantee 100% security of information. You need to understand that the system and communication network used by you to access Sunseeker Services may encounter problems due to circumstances beyond our control. Please be sure to properly keep your account number, password and other identity elements. When you use the services, we will identify you through your account number, password and other identity elements. Once you disclose the above information, you may suffer losses and it may be detrimental to you. If you find that your account number, password and/or other identity elements may or have been leaked, please contact us immediately so that we can timely take appropriate measures to avoid or reduce losses.
6. We have an industry-advanced, data-centric data security management system centered on the data life cycle, which improves the security of the entire system from multiple dimensions, including organizational construction, system design, personnel management and product technology.
IV. How to Manage Personal Information
(I) Access, update and delete
We encourage you to update and modify your information to make it more accurate and effective.
We will adopt appropriate technical means or contact channels to ensure, to the extent possible, that you can access, update and delete your own personal information or other information provided when using Sunseeker Services. Unless otherwise provided by laws and regulations, when you modify or delete your personal information, we may not immediately modify or delete the corresponding information from the backup system, but shall modify or delete the information when the backup is updated.
(II) Account cancellation
We provide the function of cancelling a registered account. You can cancel your account on the “Account Cancellation” page of Sunseeker Services by yourself, provided that it meets the conditions stipulated in the service agreement and applicable national laws and regulations.
(III) Disclosure and sharing. Many of our services allow you to publicly share information about you not only with your social network, but with all users of the services, such as the information you upload or post in Sunseeker Services, your response to the information uploaded or posted by others, the information you upload or post in the public area of Sunseeker Services that is not visible to specific users, and location data and log information related to such information. As long as you do not delete the information that you have made public or shared, it may remain in the public domain. Even if you delete the shared information, it may still be cached, copied or stored independently by other users or third parties not under our control, or kept in the public domain by other users or such third parties. We will not be responsible if you disclose or share information through the above channels and result in the leakage of your information. Therefore, we remind you and ask that you carefully consider whether you will disclose or share your information through these channels. Please be advised that information such as your completed profile and posts may be publicly displayed on your personal homepage.
(IV) Change the scope of your authorization and consent. You can always choose whether to disclose information. Some information is necessary to use Sunseeker Services, but most other information is provided at your discretion. You may change the scope of your authorization to continue collecting information or withdraw your authorization by means such as deleting information and turning off device functions. After you withdraw your authorization, we cannot continue to provide you with the services for which you have withdrawn your authorization, and we will no longer process your information. However, your decision to withdraw your authorization shall not affect the processing of information based on your previous authorization.
(V) Obtaining copies of personal information. If you need a copy of your personal information, you can contact us through the feedback channel. After verifying your identity, we will provide you with a copy of your personal information in our services (including basic and identity information), except as otherwise provided by laws and regulations or otherwise agreed in this Policy.
V. Third-Party Services
Sunseeker Services may be connected to or linked to services provided by third parties (including websites or other forms of services). It includes:
(1) You can use the “Share” button to share certain content (such as articles and updates) from Sunseeker Services to third parties. Alternatively, you can log in to Sunseeker Services with a third-party service. These functions may collect information about you (including your log information) in order to function properly as described above;
(2) We provide you with links through advertisements or other means of our services that allow you to access third party services or websites;
(3) Other situations with access to third-party services. For instance, we may access third-party services or other similar applications (such as embedded code and plug-ins) to improve customer service and user experience for the purposes stated in this Policy. Currently, the third-party vendors we access mainly include the following types:
1. For advertising-related services, including advertising display, advertising statistics and monitoring;
2. For message push functions, including push from mobile phone manufacturers and event-specific alerts;
3. For payment-related services, including order payment, transaction behavior verification, income settlement, payment information summary statistics;
4. For obtaining device location permissions and collecting device and log information with your consent;
5. For third-party authorization services, including third-party account login and sharing of relevant content to third-party products;
6. For supporting product function modules, including voice recognition, intelligent customer service and content storage;
7. For optimizing product performance, including improving hardware distribution capability, reducing server cost and functional heat repair; and
8. For account security and product reinforcement related services, including network monitoring, domain name resolution, anti-hijacking, anti-trash and anti-cheating, encryption and decryption services. Your use of third party services (including any information you provide to such third parties) is subject to the third party’s own terms of service and information protection statement (not this Policy), which you are required to read carefully. This Policy applies only to the personal information we collect, and does not apply to services provided by any third party or to their rules for the use of information. If you become aware of risks associated with these third party services, you are advised to terminate the operations to protect your legitimate interests and to contact us promptly.
VI. Protection of Minors
We recommend: Any minors who use Sunseeker Services shall obtain the consent of their parents or other guardians (hereinafter “guardians”) in advance. We will protect information about minors in accordance with applicable national laws and regulations. Guardians are encouraged to direct minors to use Sunseeker Services. If you are a minor under the age of 14, please notify your guardian and seek its consent and guidance before you use Sunseeker Services and submit personal information.
VII. Notices and Amendments
In order to provide you with better services, we may modify the terms of this Policy from time to time in accordance with updates to Sunseeker Services and relevant legal and regulatory requirements, and post any changes to this Policy on this page. Such modifications shall form part of this Policy. For significant changes, we will also provide a more prominent notice (including website announcements, push notifications and pop-up alerts). Significant changes referred to in this Policy include, but are not limited to:
1. Significant changes to our service model; such as the purpose of processing personal information, the type of personal information processed, and the use of personal information;
2. Significant changes to our ownership structure; such as changes in owners caused by business adjustments, bankruptcy, and mergers and acquisitions;
3. Significant changes to the main objects of personal information sharing, transfer or public disclosure;
4. Significant changes to your right to participate in the processing of personal information and the way in which you exercise it;
5. Significant changes to the responsible departments, contact details and complaint channels for handling personal information security; and
VIII. How to Contact Us
Sunseeker Technology Co., Ltd will protect your personal information in accordance with this Policy. If you have complaints and reports regarding cybersecurity, or if you have any questions, comments or suggestions regarding this Policy and your information, and questions about the privacy practices of Sunseeker Services, please feel free to contact us by sending an email to email@example.com. In general, we will address your questions, comments or suggestions within fifteen business days of receipt and verification of your user identity. If you are not satisfied with our process, you can file a complaint or report to the government department that governs personal information protection.