For Readers from non-PRC Area
Updated December 2023
Wuhan HongShan Huanxia Technology Co., Ltd., which provides administrative and other services to various HongShan entities, and HongShan entities (“HongShan”, “we”, “our”) are committed to protecting and respecting your privacy and ensuring that your personal data is processed fairly and lawfully in line with all relevant data protection legislation. This Privacy Notice sets out the principles governing the use of your personal data that may be collected, received, used, stored and disclosed in connection with your use of our websites and online properties (the “Websites”).
HongShan’s processing of your personal data may be subject to data protection laws in the European Economic Area (the “EEA”), the United Kingdom (the “UK”) and the United States of America (the “U.S.”), including the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), the UK General Data Protection Regulation (the “UK GDPR”), the UK Data Protection Act 2018 (the “DPA18”) and the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA” and together with the CCPA, “CCPA/CPRA”). Under the GDPR, the UK GDPR and the DPA18, we are the “controller” of your personal data, and under the CCPA/CPRA, we are characterized as a “business” in our use of personal data.
WHAT PERSONAL DATA DO WE USE?
HongShan may collect, receive, use, store, transfer and otherwise process the following personal data about you in connection with the Websites:
• Usage Data, such as information about how you use our Websites, products and services.
• Geolocation Data, such as geographic location information about a particular individual or device.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect personal data from and about you, including through:
• Automated technologies or interactions. As you interact with the Websites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
You may be requested to provide some or all of the personal data described in this Privacy Notice in connection with your use of the Websites. If you fail to provide certain information when requested, and this personal data is necessary for us to comply with our legal and regulatory obligations, to perform the contract we have entered into with you or to manage our relationship with you, we will not be able to continue your involvement with the Websites. In all other cases the provision of your personal data is voluntary.
HOW WILL WE USE YOUR PERSONAL DATA?
HongShan only processes personal data where we have a legal basis for doing so. Most commonly, we will rely on the following legal basis, or legal bases, to process your personal data:
• Where it is necessary for our legitimate interests (or those of a third party) and where consistent with applicable laws:
o Using essential cookies to ensure the functioning of the Websites.
o Providing you with access to content and features in the Websites.
o Administering and protecting our business, including troubleshooting, data analysis, testing, system, maintenance and support, reporting and hosting data.
• Where you have given your consent:
o Using non-essential cookies and data analytics to analyse and improve the Websites.
HOW WILL WE SHARE YOUR PERSONAL DATA?
HongShan generally may share all of the personal data that it collects with its affiliates and the employees of those affiliates for the purposes described above. In addition, we may disclose all of the personal data that we collect in one or more of the following circumstances:
• As authorised, such as by agreements related to HongShan providing services to you and as authorised by you or your representatives.
• As required to provide our services, such as with our third-party service providers, agents or contractors in connection with services that these individuals or entities perform for HongShan.
• As required to protect ourselves, such as where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our policies or as evidence in litigation in which we are involved or as otherwise permitted or required by law or regulation.
• As legally required, such as to cooperate with regulators during periodic regulatory examinations or in accordance with law enforcement requests, court orders or other judicial or administrative proceedings.
• As legally permitted, such as with any third party that acquires, or is interested in acquiring, all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganisation or otherwise. Among other activities, HongShan and its affiliates may also share personal data with its lawyers, accountants, custodians and advisors and with persons otherwise acting in a representative or fiduciary capacity on behalf of HongShan.
We do not disclose any personal data about you to non-affiliates to market to you.
HongShan may store and transfer your personal data in and to the U.S., the EEA, the UK and other jurisdictions, including to facilitate our third-party processors’ access to and/or processing of personal data, and these jurisdictions may have data protection laws that are not as protective as those in your jurisdiction. When we transfer your personal data outside the EEA and the UK, and to the extent required by the GDPR, the UK GDPR and the DPA18, we rely on appropriate or suitable safeguards to transfer your personal data, including:
• Using standard contractual clauses approved by relevant authorities as ensuring adequate safeguards for personal data.
• Obtaining your consent to transfer personal data after first informing you about the possible risks of such a transfer.
• When the transfer is necessary for the performance of a contract between you and us or if the transfer is necessary for the performance of a contract between us and a third party that is entered into in your interest.
• Where the transfer is necessary to establish, exercise or defend legal claims.
For more information, including to obtain a copy of the documents used to protect your personal data, please contact us using the information provided in the “Contact Us” section below.
HOW LONG WILL WE RETAIN YOUR PERSONAL DATA?
HongShan seeks only to retain personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, safety or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. In all cases, to determine the appropriate retention period for personal data we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
GDPR/UK GDPR/DPA18 Rights
Under applicable EU and UK laws, individuals in the EU and the UK, or to whom the GDPR, the UK GDPR or the DPA18 apply, may have a right to some or all of the following (subject to a limited number of exceptions): (i) request access to and rectification or erasure of their personal data; (ii) obtain restriction of processing or to object to processing of their personal data; and (iii) ask for a copy of their personal data to be provided to them, or a third party, in a digital format. Individuals also have the right to lodge a complaint about the processing of their personal data with their local data protection authority in the EEA or UK.
These rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to determine whether our use of your personal data needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement.
If you are an individual resident in California, the CCPA/CPRA may apply with respect to your personal data. To the extent applicable, California residents may have the right to request information about the categories or specific pieces of personal data we collect about you, as well as information about our use and disclosure of that personal data, as well as the rights to request that we delete and/or correct your personal data, and to not be discriminated against for exercising your privacy rights. Although California residents may have the right to opt out of the sale and sharing of personal data, as those terms are defined by CCPA/CPRA, HongShan does not sell or share personal data as the terms “sell” and “share” are used under the CCPA/CPRA, including personal data of individuals under 16 years of age, and we have not sold or shared your personal data in the last 12 months.
Additionally, California residents may have the right to limit the use of their SPI for to only those purposes not authorised by the CCPA/CPRA. However, HongShan only uses and discloses SPI as permitted under the CCPA/CPRA without requiring HongShan to provide you with a notice regarding the “right to limit,” as defined therein. Nevertheless, if you have further questions about our uses or disclosures of SPI, you should contact us using the information below.
Methods for Submitting Requests
If you wish to exercise any of these rights, please contact us using the information below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of the other rights described above). Similarly, if an agent makes a request on your behalf, they will be required to verify the request by submitting your written authorisation, and we may still ask that you verify your identity with us before we can proceed with the request. We will not honour any requests from agents until authorisation is verified. We have these security measures in place to ensure that personal data is not disclosed to any person who has no right to receive it.
We will respond to your request within one month of receipt of your request, or otherwise within the timeline required by applicable law. In some cases, we may not be able to fulfil your request to exercise the right before this date and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request. You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights described above). In some cases, however, we may charge a reasonable fee if your request is clearly unfounded or excessive (for example, if you request multiple copies of the personal data). Alternatively, we may refuse to comply with the request in such circumstances.
SHINE THE LIGHT DISCLOSURES
California’s “Shine the Light” law permits California residents to annually request and obtain certain information free of charge about what personal data is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal data to outside parties without your consent for their direct marketing, or any other purpose, except as provided in this Privacy Notice. To make a request, please contact us using the information below.
LINKS TO OTHER WEBSITES
Links on the Websites may take you to third party sites over which we have no control. While such links are provided for your convenience, you should be aware that the personal data handling practices of the linked websites might not be the same as ours and HongShan does not accept any responsibility or liability for these policies. You should review any privacy policies on those linked websites. This Privacy Notice does not cover the information practices of any linked websites.
CHILDREN’S PERSONAL DATA
The Websites are intended for use by those over 18 years of age, and minors under the age of 13 may not use the Websites. We do not knowingly solicit or collect personal data on the Websites from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personal data to us through the Websites, we will take reasonable measures to delete such personal data from our records and to not use the data for any purpose (except where necessary to protect the safety of the child or others as required by law).
PRIVACY NOTICE CHANGES
We keep this Privacy Notice under review and reserve the right, at our discretion, to change, modify, add to or remove portions from it, and we will update the date above accordingly. On some occasions, we may also actively advise you of specific personal data handling activities or significant changes to this Privacy Notice where we are required to do so by applicable law. However, we recommend that you return to the Websites to check for any other changes to this Privacy Notice.
Wuhan HongShan Huanxia Technology Co., Ltd.
By email: ComplianceChina@hongshan.com
For Readers from PRC Area
Updated Date: Nov 6, 2023
- BASIC DEFINITIONS AND SCOPE OF APPLICATION
- HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION
- HOW WE ENGAGE THIRD PARTY SERVICE PROVIDERS TO PROCESS ON OUR BEHALF, AND HOW WE SHARE, TRANSFER, AND DISCLOSE YOUR PERSONAL INFORMATION
- HOW WE STORE YOUR PERSONAL INFORMATION
- AUTOMATED DECISION MAKING
- RESPONSE TO “DO NOT TRACK” SIGNAL
- YOUR RIGHTS
- HOW WE DEAL WITH INFORMATION ABOUT MINORS
- HOW YOUR PERSONAL INFORMATION IS TRANSFERRED GLOBALLY
- HOW WE PROTECT YOUR PERSONAL INFORMATION
- 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
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
(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 (email@example.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
(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.
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.
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.
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;
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
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.
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.
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.
13. HOW TO CONTACT US