Privacy Policy

Effective Date: May 1, 2021

Version Release Date: May 8, 2021

Shenzhen Agilewing Cloud Computing Technology Co., Ltd. (hereinafter referred to as “Agilewing” or “We”) attaches great importance to the privacy and information security of users (hereinafter referred to as “You”), whether you are an individual user or an enterprise user. We fully understand the importance of personal information to you. By using our services, you trust us with the handling of your information, so we are well aware of Agilewing’s significant responsibility and will make every effort to protect the security and reliability of your personal information.

This Privacy Policy aims to help you understand, in plain and understandable language, what information we collect, why we collect it, how we use and protect such information, and how you can manage and control your information rights.

Before registering, browsing, or using Agilewing’s services, you confirm that you have carefully read, fully understood, and accepted all terms of this Policy (minors should read this Policy accompanied by their legal guardians), especially the clauses that limit or exclude liability (including jurisdiction clauses), which will be highlighted in bold and/or underlined to draw your attention.

If you have any doubts, opinions, or suggestions, we are happy to listen and welcome you to contact us through the contact information provided in this Policy, and we will answer your questions.

This Policy will help you understand the following content:

Definitions
How We Collect and Use Your Personal Information
How We Use Cookies and Similar Technologies
How We Disclose/Share Your Personal Information
How We Protect Your Personal Information
Your Rights
How We Process Children’s Personal Information
Scope of Application
How This Policy Is Updated
Contact Information

1. Definitions

1.1 “Agilewing” or “We”: Unless otherwise specified, refers to Shenzhen Agilewing Cloud Computing Technology Co., Ltd. in this Policy.

1.2 “Third Party”: Refers to companies or individuals (i.e., non-affiliated companies) that have no relationship with us due to common ownership or control, or other unrelated individuals.

1.3 “Personal Information”: Refers to various information recorded electronically or by other means that can identify a specific natural person individually or in combination with other information, or reflect the activities of a specific natural person. The types of personal information referred to in this Privacy Policy are listed in the clause “How We Collect and Use Your Personal Information”.

1.4 “Personal Sensitive Information”: Refers to personal information that may endanger personal and property safety if leaked, illegally provided, or abused, and may easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment. The personal sensitive information involved in this Privacy Policy may include: your property information (including bank account numbers and recharge information, and other virtual property information); personal identification information (including ID card); online identification information (including account name, account nickname, email address, and passwords related to the foregoing); other information (including address book, personal telephone number, mobile phone number, travel information, web browsing history, accommodation information, and precise location information). For the above personal sensitive information listed in this Privacy Policy, to facilitate your vigilance when reading, in addition to the unified definition and listing here, we will further remind you by highlighting such as bold font, underlining, or separate indication in this Privacy Policy.

1.5 “Non-Personal Information”: Refers to information that cannot identify or be associated with an individual. It includes anonymized information (irrecoverable) and all non-personal information that has been publicly disclosed by the relevant competent authorities as an enterprise user (such as enterprise contact address, contact information, years of operation, enterprise scale, industry engaged in, main business, main products, website domain name, etc.).

2. How We Collect and Use Your Personal Information

We only collect and use your personal information for the following purposes stated in this Policy:

2.1 Helping You Register as an Agilewing User

To help you become an Agilewing user so that we can provide you with registered user services (such as logging into the personal center to view various information after becoming a registered user, or being eligible to participate in user activities such as preferential policies), you will register an account through the registration page on Agilewing. During the account registration process, you will directly provide us with personal sensitive information such as email address, mobile phone number, your set account password (encrypted), and mobile phone verification code. The email address you provide will be used as the login account for you to log in to our service page after successful registration, and we will use personal information such as email address and mobile phone number to send verification code information for you to submit to verify whether your identity is valid and to retrieve your password. You acknowledge that we collect mobile phone number and email address information to meet the real-name registration requirements of relevant laws and regulations. If you do not provide such information, you will not be able to normally use our registered user services. Of course, during the registration process, you can also choose to provide your current province and city information to facilitate us to provide you with better services. If you do not provide such information, it will not affect your registration process and use of our registered user services. If you have logged in to your Agilewing account, you can provide and improve your nickname, contact address, QQ number, and personal website information to us after logging in. You can choose to refuse to provide such information, which will not affect your normal use of Agilewing’s registered user functions. If you choose to provide it, we will protect it as associated personal information. We also kindly remind you that even if you do not provide any personal information to us, you can still browse all public information on our official website.

2.2 Providing You with Agilewing Technical Services

2.2.1 Information You Directly Provide to Us

To provide you with our basic core technical services (including CDN, content review, etc., for details, please refer to the real-time service content displayed on Agilewing’s official website), we provide an email verification method. You should be aware that all types of Agilewing’s technical services are our basic core business functions. If you do not provide email information and pass the email ownership verification, you will not be able to enjoy the basic core technical services provided by us.

2.2.2 Information We Collect When You Use the Services

To implement our core technical services, we may also collect the following information when you use the services:

Device Information: Including device name, device model, device settings, identifiers, regional and language settings, usage habits, operating system version, and settings of the device used to access the services, and device exception information;
Log Information: When you use the services provided by our website or related clients, we will automatically collect detailed usage of our services by you and save it as relevant network logs. Including your search query content, IP address, browser type, telecommunications operator, language used, access date and time, and web page records you visited;
Location Information: Including information about the device’s GPS signal or nearby WiFi access points, the region ID where the device is located, and the network service provider ID. Please note that individual device information, log information, etc., are information that cannot identify a specific natural person. However, if we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, for example, when associating the above information with your account, such non-personal information will be deemed as personal information during the combined use period. Unless we obtain your authorization or as otherwise stipulated by laws and regulations, we will anonymize and de-identify such personal information.

2.3 Providing You with Interactive Functions and Sending Business Notifications

When you communicate, provide feedback, share, or engage in other interactions with us or other users through Agilewing, we will collect and use contact information such as your submitted name (nickname), mobile phone number, and email address. When you use the technical guidance or technical support services provided by us, you need to submit work order information and interact with us through feedback; you can comment and interact through our “Q&A Community” section; we will promptly notify you after updating the User Agreement or Privacy Policy to protect your rights and interests. In addition, we will inform you of the interactive reply results between you and other users through your contact information, inform you of the feedback on the real-name authentication result of your account, the complaint and report notifications from right holders or users, and resolve the issues you feedback.

To improve our products and services and develop better services for you, we will use your personal information. However, you should be aware that in general, we only use aggregated information and statistical information that has been anonymized for this purpose, and will not identify you individually. We will use such information for data analysis, research, and audits.

The personal information we collect will be used to promote and introduce products and services to you. For example, sending commercial information content of products and services to you through email address and mobile phone number. Of course, you have the right to choose not to receive such promotion and introduction information of products and services according to the functions set by us on the page or the unsubscribe method we inform you of.

2.6 Providing You with Security Assurance

The personal information we collect will be used to ensure the security and reliability of our products and services, prevent online fraud, network attacks, and intrusions, and more accurately identify violations of laws and regulations or relevant agreement rules of Agilewing. We may use or integrate your account information, device information, software usage information, and information obtained by our affiliated companies and partners with your authorization or in accordance with the law to conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.

2.7 Exceptions to Obtaining Your Authorized Consent

In accordance with the provisions of relevant laws and regulations and personal information protection norms, we may collect and use personal information without obtaining your authorized consent in the following circumstances:

2.7.1 Related to national security and national defense security;

2.7.2 Related to public security, public health, and major public interests;

2.7.3 Related to criminal investigation, prosecution, trial, and execution of judgments;

2.7.4 Necessary to protect the major legitimate rights and interests such as life and property of the personal information subject or other individuals but it is difficult to obtain your consent;

2.7.5 The collected personal information is voluntarily disclosed by you to the public;

2.7.6 Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure, and other channels;

2.7.7 Necessary to sign a contract at your request;

2.7.8 Necessary to maintain the safe and stable operation of our products or services, such as discovering and disposing of faults of products or services;

2.7.9 Information obtained by technically processing your personal information so that your identity cannot be identified and the processed information cannot be recovered (not belonging to personal information); or when your personal information is de-identified with technical processing and security is guaranteed;

2.7.10 Other circumstances stipulated by laws, regulations, or relevant norms.

3. How We Use Cookies and Similar Technologies

3.1 Cookies

To ensure the normal operation of Agilewing, provide you with a more convenient access experience, and recommend content or advertisements that may be of interest to you, we will store small data files called Cookies on your computer or mobile device. Cookies usually include identifiers, site names, and some numbers and characters. For example, with the help of Cookies, websites and clients can store data such as your registered account, email, password (encrypted), and preferences. Cookies can also help us count traffic information and analyze the effectiveness of page design and advertisements. Agilewing enables Cookies for the same purpose as most websites or Internet service providers, that is, to improve user experience. We will not use Cookies for any purpose other than those stated in this Policy. You can manage or delete Cookies according to your preferences. You can clear all Cookies stored on your device through the built-in functions of various browsers, but if you do so, you need to manually change user settings every time you use Agilewing. You can refuse or manage Cookies by modifying your device’s browser settings.

3.2 Web Beacons and Pixel Tags

In addition to Cookies, we may also use other similar technologies such as web beacons and pixel tags. For example, emails sent to you may contain click URLs linked to us. If you click on the link, we will track the click to help us understand your preferences for products or services and improve customer service. Web beacons are usually transparent images embedded in websites or emails. With the help of pixel tags in emails, we can know whether the email has been opened, helping us determine the number of emails sent to users or whether to send emails to users. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.

4. How We Disclose/Share Your Personal Information

4.1 When to Disclose/Share and to Whom We May Disclose/Share

Without your consent, we will not disclose or share your information to third parties. After obtaining your consent, to provide you with services, we may disclose or share your information to the following entities in the following circumstances:

4.1.1 Sharing with your explicit consent or authorization, or at your active choice.

4.1.2 Affiliated Companies: Your personal information may be shared with Agilewing’s affiliated companies. We will only share necessary personal information, which is subject to the purposes stated in this Privacy Policy. If an affiliated company intends to change the purpose of processing personal information, it will seek your authorized consent again.

4.1.3 Sharing with Authorized Partners: To achieve the purposes stated in this Policy, some of our services will be provided by authorized partners. We may share some of your personal information with partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share the personal information necessary to provide the services. Our partners have no right to use the shared personal information for any other purposes.

4.1.3.1 Sharing with advertising and statistical analysis partners for ad targeting. Agilewing will only provide these partners with user profile tags that cannot identify you personally and de-identified or anonymized statistical information to help them improve ad targeting efficiency without identifying you personally. Unless permitted by you, we will not share your personal identification information (referring to information that can identify you, such as name or mobile phone number, through which you can be contacted or identified) with partners that provide advertising and analysis services.

4.1.3.2 Sharing with suppliers, service providers, and other partners. We send information to service providers, smart device suppliers, system service providers, and other partners that support our business (such as hardware manufacturers, telecommunications operators, cloud service providers). These supports include providing technical infrastructure services, analyzing the use of our services, providing customer service, investigating illegal and irregular incidents, facilitating payments, or conducting academic research and investigations. We will sign strict data protection agreements with the shared entities, requiring them to process personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures. If we share your personal sensitive information or if the authorized partner changes the purpose of using and processing personal information, we will seek your authorized consent again.

4.1.4 Sharing in Legal Circumstances: We may share and disclose your personal information in accordance with the provisions of laws and regulations, the needs of litigation and dispute resolution, or the legitimate requirements of administrative and judicial authorities.

For example, if we determine that you have violated laws and regulations or seriously violated the relevant agreement rules of Agilewing, or to protect the personal and property safety of Agilewing, its affiliated companies’ users, or the public from infringement, we may disclose your personal information in accordance with laws and regulations or the relevant agreement rules of the platform, including relevant violations and the measures taken by Agilewing platform against you. For example, if the account you use or any content such as illegal videos or violating videos uploaded by you seriously violates our platform rules, violates laws and regulations, and/or violates public order and good customs, causing significant social impact and reputational loss to our platform, we may publicly disclose your information and punishment.

4.2 Transfer of Information and Exceptions

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

4.2.1 Transfer with explicit consent.

4.2.2 In the event of merger, acquisition, or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new company or organization that holds your personal information to continue to be bound by this Privacy Policy; otherwise, we will require the company or organization to seek your authorized consent again.

4.3 Public Disclosure

We will only publicly disclose your personal information under the following circumstances and on the premise of taking industry-standard security protection measures:

4.3.1 Disclose the personal information you specify in the disclosure method you explicitly agree to according to your needs.

4.3.2 In cases where it is necessary to provide your personal information in accordance with the requirements of laws and regulations, mandatory administrative law enforcement, or judicial requirements, we may publicly disclose your personal information in accordance with the required type of personal information and disclosure method. On the premise of complying with laws and regulations, when we receive a request for such disclosure of information, we will require the corresponding legal documents, such as subpoenas or investigation letters, to be issued. We firmly believe that the information required of us should be as transparent as possible within the scope permitted by law. We will carefully review all requests to ensure they have a legal basis and are limited to data that judicial and law enforcement authorities are legally entitled to obtain for specific investigation purposes.

4.4 Exceptions to Obtaining Authorized Consent in Advance When Sharing, Transferring, or Publicly Disclosing User Information

In the following circumstances, sharing, transferring, or publicly disclosing your user information does not require obtaining your authorized consent in advance:

4.4.1 Related to national security and national defense security;

4.4.2 Related to public security, public health, and major public interests;

4.4.3 Related to criminal investigation, prosecution, trial, and execution of judgments;

4.4.4 Necessary to protect the major legitimate rights and interests such as life and property of you or other individuals but it is difficult to obtain personal consent;

4.4.5 Personal information voluntarily disclosed by you to the public or provided to trading counterparts;

4.4.6 Collecting personal information from legally publicly disclosed information, such as news reports, government information disclosure, and other channels;

4.4.7 Evaluation information or information that must be disclosed in accordance with laws and regulations. For example, to build a trustworthy trading environment in the cloud market, your credit evaluation information (star rating, customer reviews) needs to be publicly shared. If you are a service provider, you should publicly share relevant information of the enterprise or natural person operator in accordance with the requirements of applicable laws and regulations and market rules;

4.4.8 Other circumstances stipulated by laws and regulations.

5. How We Protect Your Personal Information

5.1 Security Exceptions

We have adopted reasonable physical and technical measures to protect the information collected in connection with the services. However, please note that although we have taken reasonable measures to protect your information, no website, Internet transmission, computer system, or wireless connection is absolutely secure. Please properly protect your personal information and only provide it to others when necessary. If you find that your personal information has been leaked, especially if your account and password have been compromised, please contact our online customer service immediately so that we can take corresponding measures.

5.2 Security Measures We Take

We have used industry-standard security protection measures to protect the personal information you provide, preventing data from being unauthorized accessed, publicly disclosed, used, modified, damaged, or lost. We will take all reasonable and feasible measures to protect your personal information. In particular, we have taken the following measures:

5.2.1 We will de-identify the personal information we collect from you, thereby reducing the risk of other organizations or individuals identifying you through de-identified personal information. We use SSL encryption for many services. We will review practices related to information collection, storage, and processing (including physical security measures) to prevent unauthorized access to various systems.

5.2.2 We only allow Agilewing employees and personnel of authorized service companies that need to know the information to process personal information to access the personal information, and they are required to fulfill strict contractual confidentiality obligations and receive relevant security training from time to time. If they fail to fulfill these obligations, they may be held legally responsible or their relationship with Agilewing may be terminated.

5.2.3 The security of your information is very important to us. Therefore, we will continuously strive to ensure the security of your personal information and implement security guarantees such as full-process security encryption for storage and transmission to prevent your information from being accessed, used, or disclosed without authorization. At the same time, the specific content of certain encrypted data can only be accessed by the user themselves, and no one else has the right to access it. When transmitting and storing your personal sensitive information, we will adopt security measures such as encryption; when storing personal biometric information, we will store it after technical processing, such as only storing the summary of personal biometric information.

5.3 Emergency Response to Security Incidents

After a personal information security incident occurs, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedies for you. We will promptly inform you of the relevant situation of the incident through email, letter, phone call, push notification, etc. If it is difficult to inform each personal information subject one by one, we will issue an announcement in a reasonable and effective manner. At the same time, we will take the initiative to report the disposal of the personal information security incident in accordance with the requirements of the regulatory authorities.

5.4 Retention Period and Region

During your use of Agilewing, we will continuously retain your personal information, but the relevant information will be retained for the minimum time necessary to achieve the purpose; otherwise, we will delete or anonymize the source data and backup data of the personal information. If you cancel your account or take the initiative to delete the above information, Agilewing will continue to retain your information for 6 months after your deletion in accordance with the provisions of the Cybersecurity Law and other laws and regulations. Agilewing will store the personal information collected and generated during domestic operations within the territory of the People’s Republic of China in accordance with the provisions of laws and regulations, and will not transmit such information overseas. If Agilewing needs to transmit it overseas due to business development, it will clearly inform you and obtain your consent.

6. Your Rights

6.1 Right of Access to Personal Information

You have the right to access your personal information, except for exceptions stipulated by laws and regulations. If you want to exercise the right of data access, you can log in to your account on the Agilewing website. Specifically, you can access the information under your account through “Personal Panel – Personal Information” on Agilewing.

6.2 Right to Correction of Personal Information

When you find that the personal information about you processed by us is incorrect, you have the right to request us to correct it or correct it yourself by logging into your account and changing your personal information through “Personal Panel – Personal Information/Security Settings” on Agilewing. When updating your personal information, we may require you to verify your identity first (such as sending verification information to your email address or mobile phone number) before processing your request.

6.3 Right to Erasure of Personal Information

You can request us to delete your personal information in the following circumstances:

6.3.1 If our processing of personal information violates laws and regulations;

6.3.2 If we collect and use your personal information without obtaining your consent;

6.3.3 If our processing of personal information violates the agreement with you;

6.3.4 If you no longer use our products or services, or you cancel your account;

6.3.5 If we no longer provide you with products or services.

6.4 Changing the Scope of Your Authorized Consent

Each business function requires certain basic personal information or device permissions to be completed. For the collection and use of additional collected personal information, as well as device permissions that you consider unnecessary at that time, you can give or withdraw your authorized consent at any time through online customer service or in-site message, and we will reply in a timely manner. When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw consent will not affect the personal information processing carried out based on your authorization before.

6.5 Right of the Personal Information Subject to Obtain a Copy of Personal Information

Within the scope permitted by laws and regulations, you have the right to obtain a copy of your personal information, which can be processed by contacting online customer service. On the premise of technical feasibility and reasonable cost, we can also directly transmit a copy of your personal information to a third party designated by you in accordance with your explicit request.

6.6 Restricting Automated Decision-Making by Information Systems

In certain business functions, we may make decisions only based on non-manual automated decision-making mechanisms including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to request us to explain, and we will also provide appropriate remedies. When you have other complaints, suggestions, or related questions, please contact Agilewing through the contact information in this Policy. We will review the relevant issues as soon as possible and reply in a timely manner after verifying your user identity, generally within thirty days. Of course, if you are not satisfied, you can also file a complaint or report to the competent authority. In principle, we will not charge fees for your reasonable requests, but we may charge a certain cost fee for repeated requests beyond a reasonable limit. We may refuse requests that are unreasonably repetitive, require excessive technical means (for example, need to develop new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are very impractical. In addition, if your request is directly related to national security, national defense security, public health, criminal investigation, and other matters directly related to public interests, or may cause serious damage to the legitimate rights and interests of you or other individuals or organizations, we may not be able to respond to your request.

6.7 Right to Be Informed of Cessation of Operations

If Agilewing terminates services or operations, we will promptly stop collecting your personal information, and will notify you of the cessation of operations at least thirty days in advance by means of individual delivery or announcement, and delete or anonymize your personal information held by us after terminating services or operations.

7. How We Process Children’s Personal Information

Agilewing’s products and services are mainly aimed at non-natural persons.

Children are not allowed to create their own user accounts without the consent of their parents or guardians. In cases where children’s personal information is collected with the consent of their parents, we will only use or publicly disclose this information if permitted by law, explicitly agreed by the parents or guardians, or necessary to protect the children. You note that we regard anyone under the age of 14 as a child. If we find that we have collected children’s personal information without first obtaining verifiable parental consent, we will immediately delete the relevant data.

8. Scope of Application

To ensure a smooth user experience, you may receive content or network links provided by third parties. We have no control over such third parties. You can choose whether to access links, content, products, and services provided by third parties. We cannot control the privacy and data protection policies of third parties, and such third parties are not bound by this Policy. Before submitting personal information to third parties, please refer to the privacy protection policies of these third parties. You should clearly understand that this Privacy Policy does not apply to services provided to you by other third parties. For example, when service providers on the Agilewing Cloud Market (such as live broadcast service providers) provide you with services relying on Agilewing, the information you provide to such service providers does not apply to this Privacy Policy. We also recommend that enterprise users who use our cloud services to provide services to your users should separately agree on a privacy policy with your users.

9. How This Policy Is Updated

Based on the ever-changing nature of the Internet, we reserve the right to update or modify this Policy from time to time. We will send you change notifications through different channels. For changes to this Privacy Policy, we will publish the latest version of the Privacy Policy on our website or a prominent position of Agilewing, or send you a separate notification (such as an electronic notification) to remind you of any changes to the Privacy Policy. Although this Privacy Policy allows adjustments, we will not weaken your rights under this Privacy Policy without your consent.

10. Contact Information

If you have any doubts, opinions, or suggestions about JAB and this Privacy Policy, you can contact us by calling the customer service hotline or submitting a work order through the Support Center. To ensure that we efficiently handle your issues and feedback to you in a timely manner, you need to submit your identification, valid contact information, written request, and relevant evidence. We will process your request after verifying your identity.