Privacy Policy
Version and Effective Date of
the Privacy Policy
Effective Date: [December 25, 2020]
Date of
latest update and issuance: [December 25,
2020]
(replacing the former version)
WELCOME TO USE OUR PRODUCTS AND
SERVICES!
Before using our Products and Services, please carefully read our
Privacy Policy. YOUR BROWSING OR USING OUR PRODUCTS SHALL BE DEEMED AS
THAT YOU FULLY ACCEPT THIS PRIVACY POLICY AND COMMIT TO COMPLY WITH
ALL APPLICABLE LAWS AND REGULATIONS.
“INTSIG”
or “We” refers to INTSIG Information Co., Ltd. with its
registered office in Shanghai PRC.
“You”
refers to the users (whether registered or not) of Our Products
and the purchasers of paid services.
“Our
Products” include software Products and services (provided by
our company and/or our branches, affiliates or partners across the
globe) in connection with the software Products we provide. The
software Products and applications we provide include [CamCard].
I.Applicability
and content of Privacy Policy
Thank you for choosing to use Our Products and services. You may use
Our Services in various ways. We hope you have a clear understanding
of how we collect and use information and what kind of measures you
may take to protect your privacy through our Privacy Policy. IF YOU
DON’T AGREE TO OUR PRIVACY POLICY, PLEASE DON’T USE OUR PRODUCTS AND
SERVICES. IF YOU HAVE BEGUN USING OUR PRODUCTS AND SERVICES, PLEASE
IMMEDIATELY CANCEL YOUR ACCOUNT AND STOP THE USE. YOUR BROWSE AND USE
OF OUR PRODUCTS MEANS YOU ACCEPT THAT THIS PRIVACY POLICY IS
APPLICABLE TO YOU.
Our Privacy Policy offers
answers to the following questions:-
(1)Collection
purpose and classification of personal information;
(2)Scope and means of information collection;
(3)Options we provide you with, including that of how to have access
to, review and update personal information and cancel the account;
(4)Use and setting of personal information;
(5)Sharing, disclosure of and making available to public the personal
information;
(6)Information security, etc.
II.Update
We
have been continuously improving Our Privacy Policy, and with the
extension of the scope of Our Products and services, we may update our
Privacy Policy from time to time. Please review our Privacy Policy
regularly to know about it in its update version. If any update
results in essential reduction of your rights under the Privacy
Policy, we will notify you by posting the reminder or announcement
where it is notable at the interface of Our Products, or e-mailing
you, before the date when the revised version becomes effective. YOUR
CONTINUED USE OF OUR PRODUCTS FROM THAT DAY ON WILL BE UNDERSTOOD AS
YOU FULLY ACCEPT THE UPDATED PRIVACY POLICY.
IF YOU DISAGREE WITH THE REVISED PRIVACY POLICY, PLEASE IMMEDIATELY
CANCEL YOUR ACCOUNT AND STOP USING OUR PRODUCTS AND SERVICES.
III.Collection
purpose and classification of personal information
1. Purpose of information collection
We provide services to you by means of website,
software and other
applications. We collect your information only for the purpose of
providing products and services to you (functions designed for each
product differs from one another; you should familiarize yourselves
with these differences and make your own privacy settings based on
your needs and the circumstance), improving your experience of using
Our Products and services, facilitating your use of Our Products and
services more expediently, obtaining the information that you need in
a faster and more accurate way, and conducting the commercial
exploration of big data application, on condition of ensuring legal
compliance and protection of privacy.
2.
Classification of information
The information
generated during your use of Our Products and
services may be categorized into the following two types by whether
the information subject is identifiable or not with the information:
(1)Identifiable personal information: mainly including the
information you submit, and it may be used to directly identify, trace, discern, and determine your true identity, such as e-mail
address and phone number, etc.
(2)Unidentifiable
personal information: mainly including the information generated
during using Our Products and services, and it may be related to you
but cannot be used to directly identify, trace, discern and determine
your true identity, such as the records of your use of Our products
and services.
3. Considerations in design of
the Products’ personal information
protection
In designing the Products’ personal
information protection, the
following factors are taken into consideration:
a)
Supply of the Products and services;
b) Security
setting of the operating system on user’s terminal
equipment (this usually refers to the different security settings in
Android and IOS systems);
c) PRC Cybersecurity Law,
EU General Data Protection Regulation and
other applicable laws and regulations and mandatory standards;
d) The level of information protection in the same industry, similar
products or existing technology and market;
e)
Recommended standards, feedback from user’s complaints; and
f) Other measures conducive to improving products and services and
improving cyber information security.
IV. Scope and means of information
collection
1. Information you submit
(1)Registration
information you submit and the information collected based on industry
practice and demand of the Products.
At the time you
register your [CamCard] account, in order to identify the user and facilitate contact, you
shall provide the real and effective information such as e-mail
address of phone number, etc. You understand and agree that under
necessary circumstances (e.g. cancel of account, etc.), we may
identify you based on your registration information, so as to prevent
any other person from using your identity to operate fraudulently
which will affect your normal use of Our Products and services.
(2)Data
information you upload
The information you may
upload business card during using our
services can be your personal information or the personal information
of others protected by laws and may related to your or other’s private
information protected by law that may involve your or other’s privacy,
or is granted protection under copyright law, etc. You
shall guarantee that you have obtained the necessary
authorization to copy and upload such data information. You will be
required to make proper setting and adopt appropriate security measure
so as to prevent the leakage of data and damage to right owner’s
interests. Please pay great attention to protecting your own or
other’s data information. You shall refrain from disclosing the data
information to the public without authorization.
2. The information we obtain during your use of Our Products and
services
In order to provide high-quality services
to you, Our Products
collect information for the purpose of performing the product service
contract based on the need of Our Products collecting the information
from the scanned business card you upload, your contacts and location,
for us to do analyzation and matching of interpersonal relations with
big data technology. We may record and analyze the use and the method
of use of our services and any other relevant information, including
hardware model and identification information, operating system
version, system activities and other device information, Internet
Protocol address, account sign-in or sign-out, clicks of
advertisements and other log information, as well as Web Beacon or
Cookies, browser version information. You may manage permission
through security software and we will try our best to seek a balance
between your permission and your experience, for instance that we may
inform you of authorizing when you first use relevant functions, but
then we will no longer inform you frequently to avoid affecting your
experience. However, you may not use the products to achieve the
purpose of net social if you disagree with the authorization. The
purpose of collecting the information of installing applications is
only for analyzing which other products would be selected for use by
our clients with Our Products. The information of operating system,
etc. is collected for security of the products, which can be in the
form of security tip to you.
Including the
information mentioned above, the information we collect
and/or use include user personal information, non-user personal
information, the information recorded by third party’s platform, etc.
You agree that the scope of information we collect mentioned above
can be properly adjusted with development of legal and regulatory
provisions, development of technology and business and user’s
feedback, etc.
V.Access
to, review and update of personal information
You can access, review and update (to ensure
that we can timely reach
you when necessary, you should process some update upon change of the
information) your personal information; However, for the sake of
security, you may only do so after you log in. In case of any changes
to your personal information, you shall timely log in your account and
update accordingly.
VI.
Cancellation of personal account
You may contact us at [support@intsig.com] to cancel your account. We
will respond to your request within a
reasonable time. After cancelation of your account, we are not obliged
to keep or provide information under your account. Except as otherwise
provided by law, we will delete your personal information if so
requested by you.
VII.Use
and setting of personal information
By using Our Products and services, you consent
to and grant
authorization to our collection and processing your information,
including the device and software user information, personal
information and content information uploaded by user (mainly the image
information you uploaded; regarding the uploaded content, you warrant
that you have the intellectual property involved therein or have
obtained the relevant license and there is no infringement of third
party’s right). The information is only used for the optimization of
software interface interaction. No specific information will be used
or disclosed.
You understand and agree that
the information you make public
(because of your own choice or our default setting, e.g. the document
or user name you share) may be browsed, reposted and commented by
other users of our services. You may protect your critical information
by deciding whether to upload certain information, and whether to turn
on the specific function of Our Products. To prevent harassment due to
abuse of personal information by others, we suggest you pay attention
and soon familiarize yourself with the function setting of Our
Products. The default setting is offered in consideration of various
factors including industry customs, general need of most users and
product form, etc. It is possible that what suits most users does not
meet your particular need. YOU UNDERSTAND AND AGREE THAT, GIVEN THAT
THE SERVICES WE PROVIDE INCLUDE SOCIAL NETWORKING WEB SERVICES, THE
DEFAULT SETTING OF OUR PRODUCTS MAY MAKE YOUR PERSONAL
INFORMATION AVAILABLE TO THE PUBLIC IN ORDER TO IMPROVE
USER EXPERIENCE, AND SUCH DEFAULT SETTING MAY ENABLE ANY OTHER PERSON
TO HAVE ACCESS TO OR OBTAIN YOUR PERSONAL INFORMATION.
If we use your information under any circumstance other than that
specified herein, we will obtain your prior consent.
When you share a business card with your friends or share it on
social media, others can see your complete business card information,
such as name, company, job title, cell phone/phone number, e-mail
address, company address, and so on.
Our Products
will ask you for the following permissions during
regular operation:
1. Storage: Having access
to device storage in order to read and
manage business card
2. Camera & Album: Using
your device’s camera and photo album to
take photos and for the functions of auto crop and exchange of cards
via QR Code
3. Contacts: Accessing device contacts
to use the function of
importing phone contacts and saving card to contacts
4. Location: Accessing device location to exchange cards via Card
Radar
5. Microphone: Using your microphone for
making note via voice
6. Calendar: Accessing and
storing calendar information for the
reminder function
7. Cookies: When accessing our
webpage (www.camcard.com), we use
cookies to provide you with necessary services.
It is required to grant these permissions otherwise the stated
functions may not work as intended.
Purpose of
and Privacy Policy/Statement or relevant content, of
third-party cooperation
those available in
Chinese:
Facebook：https://www.facebook.com/business/gdpr
iCloud：https://www.apple.com/legal/privacy/szh/
Outlook：https://privacy.microsoft.com/zh-CN/privacystatement
those available in English:
for data sharing and sync storage for business card
Facebook：https://www.facebook.com/business/gdpr
Whatsapp：https://www.whatsapp.com/legal/#privacy-policy
Twitter：https://twitter.com/en/privacy
iCloud：https://www.apple.com/legal/privacy/en-ww/
Outlook：https://privacy.microsoft.com/en-us/privacystatement
Salesforce：https://www.salesforce.com/company/privacy/
for data statistics and collection of breakdown
issues
Fabric:
https://fabric.io/dpst.pdf?utm_source=blog&utm_medium=blog&utm_campaign=fabric_gdpr
Our Products may have the function of user information display. For
the purpose of performing contract, we collect and use your
information to operate or improve our service and assist our user in
managing interpersonal relations, online networking and interpersonal
relations development by application of technology. You agree that in
certain countries and regions, as to the information you make public,
we can apply the big data technology for relevance and matching
practice, so as to, for example, provide to you user information
service, prevent unnecessary repeated input of same information in
using Our Products and services, provide to you customized content,
etc. The result of the relevance and matching practice may be
incorrect. PLEASE USE YOUR INDEPENDENT AND PRUDENT JUDGMENT IN USING
THE SERVICES. YOU AGREE THAT WE WILL NOT ASSUME ANY LIABILITY
REGARDING ACCURACY OF THE RESULT.
VIII.Big
data application
Our social networking products and other services may experience
business exploration on big data application along with trends of
information society. Upon it is confirmed that our contemplated
disposal of data resources is in compliance
with
applicable laws and regulations after compliance review, we may
process data mining, processing and matching. We understand user’s
concern of protection of personal information and privacy and fully
note that the potential legal risk if it is held by authority that
there is legal compliance issue and commit that all attempts in this
regard will be made upon confirmation that our contemplated disposal
of data resources is in compliance with
applicable laws and regulations after compliance review.
IX. Sharing personal information and third-party
service
Unless otherwise provided herein, we will not share your personal
information with any entity other than INTSIG or affiliates, partners or solution providers without your consent, and in particular, we
will not sell, lease or otherwise distribute your information. In case
you find there is steal, sale or unauthorized storage of personal
information, please report to us and provide as many clues as possible
so that we can investigate and deal with the matter. As a portion of
our services may be provided to you as a result of our cooperation
with abovementioned relevant companies, you consent to our provision
of your information to the foregoing relevant companies for the
purpose of providing you with the corresponding services. Such
relevant companies only use your information for the purpose of
providing corresponding services. We guarantee the safe use of such
information by entering into confidentiality agreement or including
confidentiality provisions in the contract with such relevant
companies. During your use of relevant services, such relevant
companies will also undertake the same responsibilities as those we
undertake in order to protect the security of your information. If the
relevant companies fail to protect your information security, we will
pursue their default liability, etc. according to law and contract and
we will also probably reach you for negotiation to have your
authorization that we can pursue any other party’s legal liability,
for and on behalf of you, relating to your right of being protected
for the personal information.
Our Products may
support third-party service and we may replace when
necessary third-party service supplier. You understand and agree that
if you use third-party service via Our Products, protection of your
personal information will be subject to the third-party’s Privacy
Policy.
X.Disclosure
of and making available to public the personal identity
information
We respect and protect your privacy and undertake that we will not
disclose a user’s personal identity information to any third-party
entity or person except as stated in the Privacy Policy, unless: -
1. You agree to make your personal information available to public
including but not limited to in the default setting or other setting
you adjusted the Products to;
2. User’s personal
information is provided according to law, or
required by governmental or judicial authority; or
3. In case of emergency and where necessary, the information is
required to be disclosed in order to protect the lawful rights and
interests of INTSIG or other users or the public security and public interest.
Under the circumstances described in the above Sub-clauses 2 and 3,
we will do our best to notify you on the disclosure. You understand
and agree that the notification to you will be made in the principles
of promptness and integrity, BUT IF IT
CANNOT BE TIMELY MADE DUE TO OBJECTIVE FACTOR OR FOR
REASONABLE CAUSE, WE WILL NOT ASSUME ANY RESPONSIBILITY FOR
THAT.
XI. Privacy protection in
bankruptcy/sale/merger
In case of sale of company assets, merger with another business
entity or bankruptcy filing, etc., the information we collect in
providing services may be assigned as part of our assets, and any
other entity assigned with this part of assets may continue to use the
information according to law and the Privacy Policy.
If your trust in us changes upon the abovementioned assignment, you
can cancel your account according to the existing rules.
XII.Information
security
We take various security technologies and measures to protect the
information and data stored in systems against authorized access, use
or disclosure of the same. For instance, the safe channel for
information you send through Our Products or website to us is
protected by TLS (an updated edition of SSL, with 2048-bit RSA and
256-bit AES encryption), and the information you store in the server
is safeguarded with AES 256-bit encryption, a bank-grade security
standard. Specific technical measures will be adjusted from time to
time with the technical and business development.
We will use our best efforts to protect the security of your
information. However, despite all the abovementioned
security technologies and measures we have been taken, we appreciate
your understanding that THERE IS NO
SECURITY MEASURE IN THE INFORMATION NETWORK THAT WORKS
AGAINST ALL KINDS OF RISKS
due to the complexity of security environment of Internet. You may
visit Security & Protection [https://www.camcard.com/site/security] to
further understand our information security policy.
We perform our obligation on cyber security of information under the
PRC Cybersecurity Law. Please understand that there are many factors affecting
cybersecurity and for the risk of cyber security of information caused not for our reason, we should timely follow up
with technical remedy or precautionary measure as well,
BUT WE WILL NOT ASSUME ANY LIABILITY.
XIII. Remedies for divulgence
of secrets
If your personal information has been or may be leaked, destructed,
or lost, we will take remedies at once and notify you soonest possible
(via alert/announcement posted on the website, push notification,
text, telephone or e-mail) and report to the relevant authority; In
any event of leakage, destruction or loss where the threat level is
high, our remedies may include discontinuation of service for the
account involved (to be resumed soonest practicable). If our remedies
require your assistance, please assist.
If you
are aware your personal information has been or may be leaked,
please notify us in a timely manner. We will use our best efforts to
take reasonable measures to offer assistance.
XIV.Privacy
terms applicable to juveniles
We pay great attention to the security and protection of juveniles’
privacy and data. We will be unable to identify whether the user is a
juvenile unless we are expressly notified of the same. We will neither
use personal information of juveniles nor disclose personal identity
information of juveniles to any third-party, if we are informed that
the user is a juvenile, unless for the purpose of providing necessary
and emergent help or as stipulated herein. If any guardian or
interested party of the juvenile finds that there is issue of
juvenile’s information involved in Our Products, please contact us via
our customer service support to file complaint at support@intsig.com. Upon verification and
concluding we have the issue, we will soonest
possible delete information, cancel account or respond otherwise as
required. If development of relevant legislation has new demand for
protection of juvenile’s privacy, we will take further action soonest
possible and ensure our strict compliance in operation.
Exceptionally, if you are a child (i.e. under the age of 14), in order to protect children's personal information, we also issued the Children's Privacy Protection Guideline . Before you use our products or services, you and your guardian should also carefully read the Children's Privacy Protection Guideline . You may use our products or services only after obtaining the guardian's consent to the Children's Privacy Protection Guideline .
XV. Law and Jurisdiction
INTSIG will provide protection to privacy and personal information
according to the Privacy Policy made according to law. WHEN YOU BROWSE
OR USE OUR PRODUCTS, YOU AGREE THAT YOU (AND YOUR ACT OF BROWSING AND
USING) WILL BE REGULATED BY THE PRC LAWS AND YOU CONSENT TO
JURISDICTION OF THE PRC COURT. THE PARTIES AGREE THAT THE RELEVANT
DISPUTE SHOULD BE FIRST RESOLVED THROUGH NEGOTIATION, FAILING WHICH,
IT IS TO BE SUBMITTED TO THE COMPETENT COURT AT INTSIG’S DOMICILE.
XVI.Risks
and exemption
If your personal information or privacy is leaked due to any of the
following causes, we will use our best efforts to remedy or assist
you, provided, however, that you shall agree that we are not liable
for: -
1. Information divulged due to computer
virus, trojan and hacker
attack;
2. Personal information divulged because you
tell your password to
others, cause others to have your password, or share a registered
account with others; or
3. Any other divulgence of
personal information not caused by reason
of INTSIG.
XVII.Storage
of personal information
The information we collect may be stored and processed by INTSIG or
its affiliates or service providers through their servers. As Our
Products can be downloaded and used by users worldwide, the servers
may be located in China (for the purpose of this clause, excluding HK,
Macao and Taiwan) or other country/region based on the need of
providing the service.
XVIII.Special
provisions applicable to certain country/region
Regarding the personal information collected and
generated in China
(for the purpose of this clause, excluding HK, Macao and Taiwan), we
will comply with the PRC Cybersecurity Law on cross-border transfer of
personal information and important business data by operator of key
information infrastructure.
In Hong Kong
Special Administrative Region, Macao Special Administrative Region and Taiwan, Our Products and services will
comply with all applicable legal provisions of each of the regions
including but not limited to the HK
Personal Data (Privacy) Ordinance.
In the circumstance where the EU General Data
Protection Regulation
applies to the services provided by us, we commit that you will in
addition have the relevant rights and interests under the Regulation
including but not limited to right of access to data (you have the
right to obtain from us confirmation as to whether or not personal
data concerning you are being processed, where they are being
processed and for what purpose they are being processed), right to
data portability (under certain condition, we will provide to you or
another designated data controller upon your request your data in the
form stipulated by the Regulation), right to erase (under certain
condition, we will erase all personal data concerning you without
undue delay upon your request).
In the United
States, Our Products and services will comply with all
applicable legal provisions including but not limited to the
US Privacy Act, the US Electronic Communications Privacy Act and the
US Children's Online Privacy Protection Act.
If your rights and interests under the
applicable legal provisions
differ from what is stipulated herein, that part of the applicable
legal provisions prevails, provided, however, in case the
abovementioned legal provision conflicts with the mandatory provision
under the governing law of the Privacy Policy, we will on the premise
of abiding by the mandatory provision, comply with the applicable
legal provision to the extent possible.
XIX.Severability
If
there is anything herein contradicting the legal provisions
applicable to it, the legal provisions prevail over the contradicting
part. If there is anything not covered hereunder, the applicable legal
provisions will fill in and govern.
If any
clause or part of the Privacy Policy is declared or ruled
according to applicable law unlawful, invalid or unenforceable, the
other clause or other part of the Privacy Policy shall not be
affected. The Privacy Policy is to be interpreted with the unlawful,
invalid or unenforceable clause or part being deleted.
XX. Implementation of Privacy Policy
We
will regularly inspect the implementation of the Privacy Policy.
If you have any questions, suggestions, complaints or reports about
our Privacy Policy, please contact us at the e-mail address, support@intsig.com
with the e-mail subject: Issues about Privacy Policy.
We pay high level to attention to your information security and
specially have a commission of information security, which leads and
coordinates relevant departments in handling information security and
inspects our company’s risk level of information security on a
periodical basis; in the meanwhile, the head of the commission will be
the Data Protection Officer whose duty includes guarantee of our
company-wide performance in fulfilling the commitment of information
security, etc.