Privacy Policy

About Us

This Policy will help you understand the following contents:

• 1. How Do We Collect and Use Your Personal Information
• 2. How Do We Outsource, Share, Transfer and Publicly Disclose Your Personal Information
• 3. How Do We Protect and Store Your Personal Information
• 4. Your Personal Information Protection Rights
• 5. How Do We Process Minors’ and Children’s Personal Information
• 6. How Do We Update this Policy
• 7. How to Contact Us
• 8. Links Connecting to Other Websites

If you use this Website and check the agree box, it means that you accept and agree to comply with this Policy. If you do not expressly agree to this Policy, please do not make any use of this Website. For the purposes of this Policy, “Affiliates” means:
any entity that controls the Company, any entity controlled by the Company, or any entity that is under common control with the Company. “Control” means the ability to exercise direct or indirect control or influence, regardless of whether by shareholding,
contract, or other means, over the operation, management, or policy of the entity. “Entity” means any individual, company, partnership, sole proprietorship, joint venture, trust, juristic person, or other legal body or unincorporated body.

1. 1. How Do We Collect and Use Your Personal Information

1. 1. Types of personal information we collect
      • 1. If you choose or intend to choose to use our products or services, in order to make advance appointment, purchase our product or contact us, you may take the initiative to fill in and provide the Company with your personal information,
        including your name, location, mailing address, phone number and email address. We may collect various information including your contact preferences and profile information (in the case of making contact through social media).
        The purposes for the Company to collect your foregoing personal information are to carry out customer and consumer management and service, carry out the management of advertising or commercial activity and to engage in other businesses
        that are consistent with the business scope specified in the Company’s business license.
      • 2. To demonstrate to you the products or services that better meet your demands, we will collect and use your device information and service log information when you visit or use this Website, as well as your social network information
        when you link to the Company’s official account of Facebook, Instagram, Weibo and WeChat through this Website. Among others:
        1. Device information: We will, according to your specific operation during the access to and/or use of this Website, receive and record the relevant information of the device you used (including the device model, operating system
           version, device setting, MAC address and IMEI, IDFA, OAID and other device identifier, device environment, software and hardware characteristic information, such as mobile application list), and the device location information.
        2. Service log information: When you visit or use the products or services provided on this Website, we will automatically collect and record your detailed usage of the products and services on this Website and save the same as
           a service log, including the type of the browser, the IP address and the visit time.
        3. Please be aware that the device information or log information individually does not belong to the information which can be used to identify a specific natural person’s identity. If we combine this type of non-personal information
           with other information to identify a specific natural person’s identity, or use it in conjunction with personal information, then during the conjunction use, such type of non-personal information will be treated as personal
           information. Unless obtaining your authorization or otherwise prescribed by laws and regulations, we will anonymize or de-identify this type of information.
      • 3. To ensure that we are providing services to you and offering relevant benefits to you, we will collect the foregoing information and may verify your identity based on the foregoing information provided by you.

1. 2. You fully acknowledge that your consent is not required for us to collect and use your personal information under any of the following circumstances that:
      • 1. It is related to our performance of the obligations under the laws and regulations;
      • 2. It is directly related to national security and national defense security;
      • 3. It is directly related to public safety, public health and major public interests;
      • 4. It is directly related to criminal investigation, prosecution, trial and enforcement of judgments;
      • 5. It is for the purpose of safeguarding the major legitimate rights and interests of the subject of personal information or other individuals, such as their life and properties, but it is difficult to obtain the consent of the principal;
      • 6. The personal information collected is disclosed to the public by the subject of personal information;
      • 7. Your personal information is collected from the information that is legally and publicly disclosed, such as from the channels of legitimate news reports and government information publicity, etc.;
      • 8. It is necessary for the signing and performance of the contract based on your requirements;
      • 9. It is necessary for the maintenance of the safe and stable operation of the product and/or service we provide, such as to detect or handle the failure of the product and/or service;
      • 10. It is necessary for legitimate news reporting by press;
      • 11. It is necessary for an academic research institution to carry out statistics or academic research based on the public interest, and when providing the results of academic research or description to the public, the personal information
        contained in the results is de-identified; and
      • 12. Other circumstances prescribed by the laws and regulations.

1. 3. Rules for use of your personal information
      • 1. We will use the personal information collected in accordance with this Policy and for the purpose of realizing the functions of our products or services.
      • 2. After collecting your personal information, we will de-identify the data through technical means, and the de-identified information could not be used for identifying the subject. Please acknowledge and agree that we have the right
        to use the de-identified information under this circumstance, and in the premises not to disclose your personal information, we shall have the right to analyze and commercialize the user database.
      • 3. Please be aware that all personal information you provide when using our products or services will continue to be authorized to us for use during the duration of your use of our products or services, unless you have it deleted or
        refuse our collection of your personal information through system settings.
      • 4. We will conduct statistics on the usage of our products or services and may share such statistics with the public or third parties to demonstrate the overall usage trend of our products or services; provided, however, that these
        statistics will not contain any of your identification information.
      • 5. When we display your personal information, we will desensitize your information by means of content replacement, de-identification and anonymous processing to keep your information protected and secured.
      • 6. We may use your personal information to push commercial advertisements that might be interested to you. You can unsubscribe from commercial advertisements by sending email to info@cindychao.com.
      • 7. If we wish to use your personal information for other purposes not specified in this Policy, or if information collected for a specific purpose is intended to be used for other purposes, we will seek your prior consent in the form
        of a check to be made by you on your own initiative.

1. 4. Effects of not providing personal information If you do not agree to provide us with your foregoing personal information, you may still browse the product or service information on this Website, but you might not be able to use some or all
      of the functions of this Website. Further, you might not be able to use this Website to obtain or enjoy some or all of the products, services, or related benefits that we offer.

2. 2. How Do We Outsource, Share, Transfer and Publicly Disclose Your Personal Information

1. 1. Outsourcing of processing of personal information The services provided by this Company or certain functions provided through this Website are provided by our external suppliers. For example, we will engage a service provider to assist us
      in providing customer support.We will enter into confidentiality agreements with the companies, organizations and individuals which are outsourced to processing the personal information provided by us, requiring them to process the personal
      information in accordance with our instructions, this Policy and any other related confidentiality and security measures.

1. 2. Sharing
      • 1. We will not share your personal information with any company, organization or individual other than this Company, unless we have obtained your explicit consent. Currently, we will seek your consent for sharing your personal information
        under the following circumstances:
        1. After obtaining your consent, we may share your name, location, mailing address, phone number, email address, contact preferences and profile information with our Affiliates; provided, however, that we will only share your
           aforementioned personal information for legal, legitimate, necessary, particular and specific purposes and will only share the personal information necessary for our provision of services. If our Affiliates wish to change
           the purpose of processing personal information, they will seek your consent again. We share such information for the purpose of demonstrating to you the products or services that better meet your demands.
        2. After obtaining your consent, we may also share your name, location, mailing address, phone number, email address, contact preferences and profile information with necessary third parties to ensure a smooth provision of our
           products or services to you; provided, however, that we will only share your aforementioned personal information for legal, legitimate, necessary, particular and specific purposes and will only share the personal information
           necessary for our provision of services.
      • 2. We will enter into confidentiality agreements with the companies, organizations and individuals with whom we share personal information, requiring them to process the personal information in accordance with our instructions, this
        Policy and any other related confidentiality and security measures. If the shared information involves your personal sensitive information, such as your identity information and transaction information, etc., the share and use
        of such information will be stricter and we will separately obtain your express consent. In the use of personal sensitive data, we will require third parties to adopt data desensitization and encryption technologies to better protect
        the user data.
      • 3. We may, in accordance with the relevant laws and regulations, or in accordance with the mandatory requirements of the competent government departments, share your personal information with others.
   3. Transfer
      • 1. We will not transfer your personal information to any company, organization or individual, except under the circumstance that:
        1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to others;
        2. In the event of a merger, acquisition or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new company or organization possessing your personal information to continue to be subject
           to this Policy; otherwise, we will require such company or organization to seek your consent again.
   4. Public disclosure
      • We will only publicly disclose your personal information under the following circumstances:
        1. After obtaining your explicit consent;
        2. Legal disclosure: we may publically disclose your personal information to the extent compulsorily required by law, legal proceedings, litigation, or government authorities.

3. 3. How Do We Protect and Store Your Personal Information

1. 1. Our technologies and measures to protect your personal information.
      We pay great attention to the security of personal information and will take any and all reasonable and feasible measures to protect your personal information:
      • 1. We have used security measures in line with industry standards to protect the personal information you provide from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonably and feasible measures to protect your personal information, including:
      • 1. The network service of this Website adopts encryption technologies such as transport-level security protocol, and provides browsing service through HTTPS and other means to ensure the security of user data in the transmission process.
        2. This Website adopts encryption technology to encrypt and store users’ personal information, and quarantines it through isolation technology.
        3. In the use of personal information such as personal information display and personal information association calculation, we will adopt a variety of data desensitization technologies including content replacement and SHA256 to enhance the security of personal information in use.
        4. iv. This Website adopts data access permission control and multiple identity authentication technology to protect personal information and to avoid illegal use of data.
        5. This Website adopts automatic code security check and data access log analysis technology to conduct personal information security audit.
      • 2. We will take all reasonable and feasible measures to ensure that the irrelevant personal information is not collected. We will retain your personal information only for a period necessary for the purposes stated in this Policy, unless the retention period needs to be extended or is permitted by law.
      • 3. The Internet environment is not 100% secure and we will do our best to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information which results in damage to your legitimate rights and interests, we will bear the corresponding legal liabilities.
      • 4. In the event of an unfortunate personal information security incident, we will, in accordance with the laws and regulations, promptly inform you of the basic situation of the security incident and its possible impacts, the measures we have taken or will take to deal with it, the suggestions that you can independently use to prevent and reduce risks, the remedial measures for you, etc. We will timely inform you of the relevant information by email, letter, phone call, push notification or other manners. If it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to publish the announcement. At the same time, we will also take the initiative to report the handling of personal information security incidents in accordance with the requirements of supervision departments.

1. 2. Storage of your personal information
      In principle, the personal information we collect and generate within the People’s Republic of China will be stored within the People’s Republic of China. We may provide products or services through resources and servers outside the People’s Republic of China, and share your personal information with our Affiliates or outsourced manufacturers outside the People’s Republic of China. This means that, after obtaining your consent, your personal information may be transferred to, or accessed from, foreign jurisdictions in the country/territory in which you use the products or services.Such jurisdictions may have different data protection laws or even no relevant laws. In such circumstances, we will ensure that your personal information is adequately and equally protected within the People’s Republic of China. For example, we may ask for your consent to the cross-border transfer of personal information, or implement security measures such as data de-identification prior to cross-border data transfer.

4. 4. Your Personal Information Protection Rights

1. 1. Under the relevant laws, regulations, national standard and local standard of the People’s Republic of China, you have the following rights which you may exercise with respect to your personal information:
      • 1. Access to your personal information, unless there are exceptions provided by laws and regulations.
      • 2. Request that we provide you with a copy of your personal information.
      • 3. Request that your personal information be supplemented or corrected.
      • 4. Amend the scope of your authorized consent. After you withdraw your consent, we will no longer process the relevant personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously conducted on the basis of your authorization.
      • 5. Request that your personal information be deleted.
        You may request us to delete your personal information under the following circumstances:
        1. i. If our processing of personal information is in violation of the laws and regulations;
        2. ii. If we collect and use your personal information without obtaining your consent;
        3. iii. If our processing of personal information is in violation of the agreement with you;
        4. iv. If you no longer use our products or services; or
        5. v. If we no longer provide you with the products or services.
        6. vi. If we decide to respond to your request for deletion, we will concurrently notify the entities which have obtained your personal information from us to delete it promptly, unless otherwise required by the laws and regulations or if such entities have obtained your authorization independently.
      • 6. Request to deregister the account. You may deregister your previous registered account at any time. After the deregistration of your account, we will cease to provide you with the relevant services, and delete your personal information at your request, except as otherwise provided by the laws and regulations.
      • 7. Request us to respond to your foregoing requests.
        With respect to your foregoing requests, you may contact us by sending an e-mail to info@cindychao.com or by calling our service number at +86 21 6329 5598. We will respond to your requests within 15 business days. For security purpose, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.However, please be aware that in principle, we do not charge you for your exercise of the foregoing rights, but for repeated requests or request beyond reasonable limit, we will collect a fee from you to cover the cost as necessary and as appropriate. As for the requests that are gratuitously repetitive, require excessive technical means (for example, require the development of new systems or radically change existing practices), pose a risk to the legitimate interests of others or are highly impractical (for example, involving information stored on backup tapes), we may reject such requests.

1. 2. We will not respond to your requests under any of the following circumstances that:
      • 1. It is related to the fulfillment of the obligations by the personal information controller as stipulated under the laws and regulations;
      • 2. It is directly related to national security and national defense security;
      • 3. It is directly related to public safety, public health and major public interests;
      • 4. It is directly related to criminal investigation, prosecution, trial and enforcement of judgments;
      • 5. The personal information controller has sufficient evidence to prove that the subject of personal information has subjective malice or abuses its rights;
      • 6. It is for the purpose of safeguarding the major legitimate rights and interests of the subject of personal information or other individuals, such as their life and properties, but it is difficult to obtain the consent of the principal;
      • 7. To respond to the request of the subject of personal information will cause serious damage to the legitimate rights and interests of the subject of personal information or other individuals or organizations; or
      • 8. Trade secret in involved.

5. 5. How Do We Process Minors’ and Children’s Personal Information

1. 1. Our products and services are aimed at adults. If you are a minor or are otherwise lacking of full legal capacity to consent to this Policy, you must obtain the explicit consent of your legal representative or guardian before you may use this Website.In cases where the personal information of a child is collected with the consent of the child’s parent or guardian, we will only use or publicly disclose such information if it is legally permitted, with the explicit consent of the parent or the guardian, or if it is necessary to protect the child.Although the definitions of children by local laws and customs are different, we treat anyone under the age of 14 as a child. If we find ourselves collecting children’s personal information without prior verifiable parental consent, we will try to delete the relevant data as soon as possible.

6. 6. How Do We Update this Policy

1. 1. We reserve the right to amend this Policy from time to time and to post the updated privacy policy on this Website. Without your express consent, we will not reduce your rights enjoyed under this Policy. We will post any change to this Policy on this page. If, after we have published any amendment to this Policy, you continue to use this Website, your continued use shall be deemed as your consent to the updated privacy policy to apply to your continued use of this Website.

7. 7. How to Contact Us

1. 1. If you have any questions regarding this Policy or wish to exercise any of your rights set out in this Policy, please send us a message to: 2nd Floor, 149 Yuanmingyuan Road, Huangpu District, Shanghai, China or info@cindychao.com.

8. 8. Links Connecting to Other Websites

1. 1. This Website may contain links, banner ads, forms, small plugins, advertisements, or other links, that connect to other websites. We bear no liability with respect to such linked websites. Any collection, use, sharing, storage and protection of your personal information by those websites will be subject to the privacy policies posted on those websites, and will not be subject to this Policy.

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