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Privacy Policy

Updated Date: Nov 6, 2023

Wuhan HongShan Huanxia Technology Co., Ltd. (hereinafter referred to as “HongShan”), its affiliates and funds (hereinafter referred to as “HongShan” or “we”) have developed this Privacy Policy to explain how we collect, use, store, share and transfer your personal information. This Privacy Policy applies to the processing of personal information in the course of your use of our website (hongshan.com, hereinafter referred to as “the Website”) and the internet services we provide to you through the website (hereinafter collectively referred to as “Services”).

This Privacy Policy only applies to the processing of personal information within the mainland of People’s Republic of China (hereinafter referred to as “Mainland China”), and shall be governed by the Personal Information Protection Law of the People’s Republic of China and other relevant laws and regulations of Mainland China (hereinafter referred to as “Relevant Laws and Regulations”).

Before you browse the Website or provide us with your personal information, you are kindly required to read and understand this Privacy Policy carefully, this Privacy Policy is closely related to your use of our Services, and we hope that you will carefully read this Privacy Policy, confirm that you have fully understood this Privacy Policy before you use our Services, and you will make appropriate choices in accordance with the guidance in this Privacy Policy. Where the provisions in this Privacy Policy are (potentially) material to your rights and interests, we have used bold font to distinguish them, please refer to them carefully. If you do not agree to any term of this Privacy Policy, you should immediately cease to use the Services and we will not be able to provide Services to you. By using our internet Services, you have read and consented to our collection, use, storage, sharing, public disclosure and protection of your relevant information in accordance with this Privacy Policy. Once this Privacy Policy is updated, we will promptly publish the latest version on the Website for your reference in a timely manner.

Please note that we have developed and implemented this Privacy Policy in accordance with the latest laws, regulations, rules and regulatory documents of Mainland China, with reference to the latest national standards to the extent possible. However, due to the possible amendments of the aforementioned laws and regulations, it cannot be ruled out that there may be varying interpretations of the same law or regulation by different regulatory departments and personnel. In the event of any inconsistency or contradiction between this Privacy Policy and applicable laws and regulations of Mainland China, the applicable laws and regulations of Mainland China shall prevail. We will also process your personal information and safeguard your personal information rights and interests in accordance with the applicable laws and regulations.

This Privacy Policy will help you understand the following:

  1. BASIC DEFINITIONS AND SCOPE OF APPLICATION
  2. HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION
  3. HOW WE USE COOKIES
  4. HOW WE ENGAGE THIRD PARTY SERVICE PROVIDERS TO PROCESS ON OUR BEHALF, AND HOW WE SHARE, TRANSFER, AND DISCLOSE YOUR PERSONAL INFORMATION
  5. HOW WE STORE YOUR PERSONAL INFORMATION
  6. AUTOMATED DECISION MAKING
  7. RESPONSE TO “DO NOT TRACK” SIGNAL
  8. YOUR RIGHTS
  9. HOW WE DEAL WITH INFORMATION ABOUT MINORS
  10. HOW YOUR PERSONAL INFORMATION IS TRANSFERRED GLOBALLY
  11. HOW WE PROTECT YOUR PERSONAL INFORMATION
  12. UPDATES TO THIS PRIVACY POLICY
  13. HOW TO CONTACT US

1. BASIC DEFINITIONS AND SCROPE OF APPLICATION

(1) Basic Definitions

Personal Information refers to all kinds of information, recorded electronically or by other means, that relates to identified or identifiable natural persons, but does not include anonymized information.

Sensitive Personal Information refers to personal information that, if leaked or used illegally, may easily lead to the infringement of the dignity of natural persons, or may seriously endanger their personal and property safety. We will separately notify you before we collect your sensitive personal information.

Personal Information Processor refers to any organization or individual that autonomously determines the purpose, means, etc. of the processing of personal information.

Unless otherwise specified, the terms not defined herein shall be have the same meaning as those of Personal Information Protection Law of the People’s Republic of China and other Relevant Laws and Regulations.

(2) Scope of Application and Exceptions

a) This Privacy Policy applies to the Services we provide, but it does not apply to products and/or services for which we have separate personal information processing rules. For the personal information collected by those products and/or services, please separately refer to personal information processing rules of those products and/or services.


b) The Services we provide may contain links to domain names of third party websites, products and services. All links containing third party websites, products and services are provided for your convenience only. We have no control over such third parties and/or their linked contents, and cannot provide any warranty, express or implied, of the linked contents, and such links cannot be treated as recommendation or authorization by us of the linked contents. Such third parties are bound by their respective personal information processing rules. As a result, you need to separately refer to such personal information processing rules provided by such parties before you submit personal information to such third parties.

2. HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

We will collect and use personal information provided in the course of your use of our Services or generated from your use of our Services in the least intrusive manner to your rights and interests, in accordance with the principles of what is proper, lawful, necessary and in good faith, for the clear and reasonable purposes stated in this Privacy Policy. If you provide personal information about anyone other than yourself, you must ensure that they are aware of how their personal information will be processed and that they have consented to having their personal information processed by us and disclosed by us to our outsourced service providers.

The collection and processing of your personal information by us is in principal based on your consent. If we intend to use your personal information for any uses or purposes other than those provided in this Privacy Policy or if there is a change in the manner or type of processing of such personal information, we will notify you in a reasonable manner and will obtain your consent before processing your personal information accordingly.

(1) We may collect or use the following types of your personal information for the following purposes and in the following manner

Communication of Financing Plans. When you send financing plans, business plans or other materials to the email address provided on the Website (bpchina@hongshan.com), we may collect your name, email address and other contact information to contact you, and personal information you provide in the email (if any, it is advised to contain only the personal information necessary for communicating with us in the content you send to this email address).

Safety Risk Control and Information Statistics. To ensure the security of network and operation of the Website, we will automatically collect information such as your device information, browser and computer or device type, access time and IP address which will be used to monitor and prevent fraud, network attacks and information theft.

(2) Reminder on Sensitive Personal Information

Your sensitive personal information will not be excluded from the information you upload in the course of using the Services we provide. Please be careful and aware of the sensitive personal information you provide. You agree that we may process your sensitive personal information for the purposes and in the manner described in this Privacy Policy.

(3) Legitimate Reasons Other Than Consent

According to Relevant Laws and Regulations, we may collect and use certain necessary personal information without your authorization or consent in the following circumstances:

a) Necessary for entering into and performing a contract to which you are a party;
b) Necessary for performing our legal duties or legal obligations;
c) Necessary in order to cope with a public health emergency or in case of emergency in order to protect the life, health and property of natural persons;
d) Processing the personal information disclosed by individuals themselves or other legally disclosed personal information within a reasonable extent in accordance with the Personal Information Protection Law of the People’s Republic of China;
e) Other circumstances provided by the laws and administrative regulations.

3. HOW WE USE COOKIES

We may use cookies to keep track of your use of the internet Services, to validate your identity, to remember your preferences, to tailor the internet Services to your access preferences and meet your interests, and to improve the quality of the internet Services. In general, you can set your browser to not accept cookies or to notify you if you are sent a cookie, giving you the opportunity to choose whether or not to accept the cookie. Please note that if you set your browser not to accept cookies, you may not be able to use some internet Services properly. We commit not to use cookies for any purposes other than those described in this Privacy Policy.

4. HOW WE ENGAGE THIRD PARTY SERVICE PROVIDERS TO PROCESS ON OUR BEHALF, AND HOW WE SHARE, TRANSFER, AND DISCLOSE YOUR PERSONAL INFORMATION

(1) Processing by Third Party Service Providers on Our Behalf

In order to provide Internet Services or use personal information as described above, we may engage other companies and individuals (collectively referred to as “Third Party Service Providers”) to process your personal information on our behalf, such as analyzing data and providing certain internet Services. We may engage the Third Party Service Providers to collect and process information such as your name and other information.

With regard to the Third Party Service Providers that we engage to process personal information, we reasonably review their ability to protect personal information, enter into a strict confidentiality agreement with such Third Party Service Providers, which shall stipulate the purpose, duration and method of engagement, types of personal information, protective measures and the rights and obligations of the parties.  We request and monitor that the Third Party Service Providers strictly comply with this Privacy Policy and have in place sufficient organizational or technical measures to protect your privacy and personal information. When the Third Party Service Providers no longer serve you, we will delete or notify the Third Party Service Providers to delete your personal information.

(2) Sharing

Sharing refers to our provision of personal information to other personal information processors who separately has independent control rights over the personal information. In general, we will not share your personal information with others, except for the following circumstances:

a) Sharing with Separate Consent: With your separate consent or at your own initiation, we may share your personal information within the scope of your authorization with a third party designated by you;
b) Sharing under Legal Circumstances: We may share your personal information in accordance with Relevant Laws and Regulations, to exercise our legal rights and interests with respect to a dispute resolution or if request by regulatory, administrative or judicial authorities in accordance with laws.

(3) Transfer

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

a) We may transfer your personal information to other parties after obtaining your express consent;
b) As part of a merger, acquisition or bankruptcy liquidation. In case of such transfer of personal information, we will require the surviving company or organization holding your personal information to continue to comply with this Privacy Policy. Otherwise, we will require such company or entity to seek authorization and consent from you again.

(4) Disclose

We may disclose your personal information only under the following circumstances:

a) After obtaining your express consent;
b) Disclosure Based on Law: We may publicly disclose your personal information as compulsorily required by laws, legal proceedings, litigations or by governmental authorities.

5. HOW WE STORE YOUR PERSONAL INFORMATION

Unless otherwise provided in this Privacy Policy, your personal information that we collect and generated in Mainland China will be stored in Mainland China.

We may store your personal information only for the duration necessary for the purposes of this Privacy Policy and as required by Relevant Laws and Regulations or regulatory authorities. We will retain web logs obtained by using technical measures to monitor and record network operating status and cyber security incidents for no less than 6 months. Unless otherwise provided by Relevant Laws and Regulations, we retain your personal information for the duration necessary for the purposes of providing Services, unless you request us to delete such information promptly or unless otherwise required by Relevant Laws and Regulations.

If we terminate Services or operations, we will immediately cease to collect your personal information and will notify you in accordance with Relevant Laws and Regulations, and delete or anonymize your personal information upon termination of Services or operations, unless otherwise required by Relevant Laws and Regulations or regulatory authorities.

6. AUTOMATED DECISION MAKING

We will not use your personal information to make automated decision making.

7. RESPONSE TO “DO NOT TRACK” SIGNAL

Most web browsers include a “Do Not Track” (“DNT”) setting, which you can activate to prevent the monitoring and collection of data about your online browsing activity. There is no uniform standard in Relevant Laws and Regulations on how DNT signals shall be interpreted and how websites and third parties who receive these setting requests should take actions. Therefore, HongShan does not honor DNT settings. However, you can control the collection and use of your usage data by setting up cookies, web beacons and similar technologies on your web browser. We will pay attention to the introduction and update of DNT requirements in Relevant Laws and Regulations on a timely basis.

8. YOUR RIGHTS
As the owner of your personal information, you have the rights to:

(1) Review or Copy Your Personal Information

Subject to Relevant Laws and Regulations, you have the right to contact our staff at any time to review and copy the personal information you provided to us.

(2) Correct or Supplement Your Personal Information

If you find any error in the personal information you provided to us that needs to be corrected or you need to supplement your personal information, you may contact our staff at any time to respond to your request.

(3) Transfer Your Personal Information

Subject to Relevant Laws and Regulations, if you request to transfer your personal information to your designated personal information processor, we will provide a means for you to transfer such information.

(4) Delete Your Personal Information

You have the right to contact our customer service staff at any time to delete your personal information. You may make a request to delete personal information under the following circumstances:

a) The purpose of processing has been achieved, cannot be achieved, or is no longer necessary to achieve;
b) We cease to provide Services, or the retention duration has expired;
c) You withdraw your consent;
d) We process personal information in violation of Relevant Laws and Regulations or agreement;
e) Other circumstances provided by Relevant Laws and Regulations.

Where the retention duration required by Relevant Laws and Regulations has not expired, or where it is technically difficult to delete the personal information, we will stop processing personal information other than storing and taking necessary security measures.

If we decide to respond to your request for deletion, we will also require our third-party business partners to promptly delete the information, unless such parties obtain your separate authorization. Please note, however, that if any information you have publicly disclosed to HongShan is captured, cached, stored, copied by other users or independent third parties that are not our business partners or our affiliates and beyond our control, or such information is uploaded or saved by other users of other applications, such information is beyond our control.

(5) Withdraw Your Consent

The Services provided by HongShan require certain basic personal information. With respect to any collection and use of additional personal information, you may provide or withdraw your consent at any time. You also have the right to withdraw your consent to our processing of personal information at any time. Any withdrawal of such consent shall not affect any processing of personal information that has already taken place. We will not refuse to provide Services for this reason except where the processing of the personal information is necessary to perform the relevant functions of the Services.

(6) Response to Your Request

You may exercise your right above by sending an email to ComplianceChina@hongshan.com. For security purposes, you may be required to provide a written request or otherwise identify yourself. We may ask you to verify your identity before we process your request.

We will respond to your request within 20 days after confirming your identity. You may contact us via the contact information set forth in this Privacy Policy. In principle, no fee will be charged with respect to your reasonable requests; however, a certain cost may be charged with respect to repeated requests or requests which exceed reasonable limits. We may deny a request if it is unreasonable, technically demanding (e.g., to develop a new system or to fundamentally change an existing practice), puts others’ legitimate interests at risk, or is impractical (e.g., relates to information stored on backup tapes).

According to Relevant Laws and Regulations, we will not be able to respond to your request under the following circumstances that:

a) Relates to the performance of our obligations under Relevant Laws and Regulations;
b) Directly relates to national security and the security of national defense;
c) Directly relates to public safety, public health or material public interest;
d) Directly relates to criminal investigation, prosecution, trial and judgment enforcement, etc.;
e) There is sufficient evidence to prove your subjective bad faith or abuse of your rights;
f) Responding to your request will cause serious damages to your legitimate rights and interests or those of other individuals or organizations;
g) Necessary to protect your or other individuals’ life, property and other significant legitimate rights and interests, but it is difficult to obtain personal authorization;
h) Relates to business secrets.

9. HOW WE DEAL WITH INFORMATION ABOUT MINORS

We do not knowingly collect personal information from minors, and we do not target the Website to minors.

10. HOW YOUR PERSONAL INFORMATION IS TRANSFERRED GLOBALLY

In principle, your personal information that we collect and generated in Mainland China will be stored in Mainland China.

If it is necessary to provide your personal information overseas, we will fulfill necessary legal obligations in accordance with Relevant Laws and Regulations, including but not limited to (if relevant) conducting security assessment on outbound data transfer, signing a standard contract on outbound transfer of personal information with the offshore recipient or conducting security certification of personal information, notifying you of the identity and contact information of the offshore recipient, purpose and method of processing, types of personal information, and the manners in which you may exercise lawful rights against the offshore recipient, and obtaining your consent to ensure that such information will receive equivalent and adequate protection as required by Relevant Laws and Regulations in Mainland China.

11. HOW WE PROTECT YOUR PERSONAL INFORMATION

We have undertaken a number of technical and organizational measures for data security to help protect your personal information from divulgement, loss, misuse or unauthorized access or disclosure.

Please kindly note that the internet is not 100% secure and we will endeavor to ensure the security of any information you send to us. In case of unfortunate personal information security incidents, we will, in accordance with Relevant Laws and Regulations, promptly inform you of: basic information and possible impacts of the security incidents, measures we have taken or will take in response to the incidents, suggestions for risk prevention and reduction you can take on your own, and the remedial measures that will be available to you, etc. We will promptly inform you of the incidents by email (if you leave relevant contact information). Where it is difficult to inform relevant persons one by one, we will publish an announcement in a reasonable and effective manner. Meanwhile, we will also report the responses to any personal information security incidents in accordance with the requirements of regulatory authorities. If your legitimate rights and interests are damaged, we shall undertake the corresponding legal liabilities.

12. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.

We will not limit any of your rights under this Privacy Policy without your express consent. We will post any changes we have made to this Privacy Policy on the relevant pages (Homepage – Bottom – Law).

In the event of any change in the processor, processing purpose, processing method, types of personal information processed, retention duration, the rights of the data subject, etc., we will inform you of the changes by email or by posting a notice in the relevant area of the Website.

Any updates to this Privacy Policy will take effect from the date stated therein.

13. HOW TO CONTACT US

If you have any question concerning this Privacy Policy, please feel free to contact us via the email address below:

ComplianceChina@hongshan.com