Zhishang Technology Group and its affiliated companies (hereinafter collectively referred to as "Zhishang Technology" or "we") have always made a solemn commitment to protecting the personal information and privacy security of users (hereinafter collectively referred to as "users" or "you") who utilize Zhishang Technology's products and services (hereinafter collectively referred to as "Zhishang Technology Services"). When you use Zhishang Technology Services, we may collect and use your relevant personal information. We hope to explain, through the "Zhishang Technology Group Privacy Policy" (hereinafter referred to as "this Policy"), the corresponding handling rules and other related matters regarding the collection and use of your personal information, so as to better safeguard your rights and interests.
This Policy applies to all Zhishang Technology Services provided by us. When you use any of our individual services, you agree to be protected by this Policy as well as the specific privacy information policy clauses (hereinafter referred to as "Specific Clauses") issued by us for that individual service. In such cases, the Specific Clauses and the clauses of this Policy shall take effect simultaneously for you. For example, users utilizing Zhishang Technology's online gaming services are subject to both this Policy and the "Privacy Protection and Personal Information Utilization Policy for Online Game Users" (see Annex 1); users under the age of fourteen are subject to both this Policy and the "Zhishang Technology Children's Personal Information Protection Rules and Guardian Guidelines" (see Annex 2). In the event of inconsistent provisions of the same nature between the Specific Clauses and this Policy, the Specific Clauses shall prevail within the scope of their constraints. If a particular individual service provided by us is not subject to this Policy, such exclusion will be clearly indicated in an appropriate manner within that service.
Before using any Zhishang Technology Services, please be sure to carefully read and thoroughly understand this Policy, especially the clauses marked in bold/bold and underlined, which you should focus on reading. Only after confirming that you fully understand and agree to this Policy should you commence using the services. If you do not agree to the content of this Policy, it may result in Zhishang Technology Services being unable to operate normally or failing to achieve the intended service effects, in which case you should immediately cease accessing/using Zhishang Technology Services. Your use or continued use of Zhishang Technology Services indicates your consent for us to collect, use, store, share, transfer, and disclose your personal information in accordance with this Policy (including updated versions).
After reading this Policy, if you have any questions regarding this Policy or matters related to it, you may contact us through the feedback channels listed in the "How to Contact Us" section of this Policy, and we will respond to you as soon as possible.
catalogue
1、 How do we collect and use personal information
2、 How do we use cookies or similar technologies
3、 Personal information that we may share, transfer, and disclose
4、 How do we store and protect personal information
5、 How to manage your personal information
6、 Third party services
7、 Protection of Minors
8、 Notification and Revision
9、 How to contact us
1、 How do we collect and use personal information
We collect your personal information mainly for the purpose of making it easier and more satisfactory for you and other users to use digital technology services. The goal of Zhishang Technology is to provide all Internet users with safe, interesting and instructive online experience. And this information helps us achieve this goal.
（1） We will collect and obtain your personal information through the following channels:
1. The information you provided. For example:
(1) The information you provide to us when registering for an account on Zhishang Technology Services or using Zhishang Technology Services;
(2) The shared information you provide to other parties through Finger Up Technology Services, as well as the information stored when you use Finger Up Technology Services.
Please note that if you disclose your information in the public areas visible to other users on the technology services, or in your responses to information uploaded or published by others, such information may be collected and used by others. When you discover that others are improperly collecting or using your information, you can contact us through the feedback channels listed in the "How to Contact Us" section of this policy.
2. Your information shared by other parties. That is to say, the shared information about you provided by other parties when using digital technology services.
3. We obtained your information. When you use Zhishang Technology Services, we collect, summarize, and record information such as log information, location information, and device information.
（2） We will collect and use the following types of personal information from you for the following purposes:
1. Help you complete registration and login
To facilitate our service to you, you need to provide basic registration or login information, including your phone number, email address, and create your account, username, and password.
In some individual services, if you only need to use basic services such as browsing and searching, you do not need to register as a user of Zhishang Technology and provide the above information; You can also fill in or supplement your other additional information (such as your nickname, profile picture, gender, hometown, occupation, education, date of birth, interests and hobbies) during registration, login or subsequent use. This will help us provide you with personalized recommendations and better service experience, but if you do not provide this information, it will not affect the basic functions of your use of digital technology services.
In addition, under the conditions stipulated in the service agreement of Zhishang Technology's individual services and relevant national laws and regulations, we also provide the cancellation of registered accounts. You can log in to Zhishang Technology Account Center (reg.163. com) to contact us for processing or follow the specific instructions for individual services.
2. Implement identity authentication
In accordance with relevant laws, regulations, and regulatory requirements, or to meet the needs of user identity verification, system and service security, and other specific service functions, we may require you to provide real identity information (such as name, ID card, passport, driver's license, household registration book, facial features, fingerprints, and other identity information) to complete identity authentication. If you do not provide the above information, we will not be able to provide you with the relevant functions and services.
To achieve the purpose of identity authentication, you agree and authorize us to provide, query, and verify your aforementioned identity information to relevant identity authentication agencies (such as personal credit reporting agencies, government departments, etc.) on our own or by entrusting third parties.
3. Maintain the normal operation of basic functions
During your use of our services, in order to identify abnormal account status, understand product compatibility, provide you with basic services such as browsing and searching, and maintain the normal operation of basic functions, we may automatically collect and store information about the services you use and how you use them, and associate this information, including:
(1) Log information: When you use our services, we may automatically collect detailed usage information of our services as relevant network logs for storage. For example, your login account, search query content, IP address, browser type, telecom operator, network environment, language used, visit date and time, and your browsing history of web pages visited, push opening history, dwell time, refresh history, publishing history, attention, subscription, bookmarking, and sharing.
(2) Device information: We may receive and record device related information (such as IMEI, MAC, Serial, SIM card IMSI identification code, device model, operating system and version, client version, device resolution, package name, device settings, process and software list, unique device identifier, software and hardware feature information), device location related information (such as IP address, GPS location, and WLAN access point, Bluetooth, and base station sensor information that can provide relevant information) based on the specific permissions you grant during software installation and use.
At the same time, in order to collect the basic personal device information mentioned above, we will apply for permission to access your device information. We collect this information to provide you with our basic services and functions. If you refuse to provide the above permission, it may result in you being unable to use the digital technology services.
Please note that individual device information and log information cannot identify the identity of a specific natural person. If we combine this type of non personal information with other information to identify the identity of a specific natural person, or use it in conjunction with personal information, during the period of combined use, this type of non personal information will be considered personal information. Unless authorized by you or otherwise provided by laws and regulations, we will anonymize and de identify this type of personal information. During the period of combined use, this information will be treated and protected as your personal information in accordance with this privacy policy.
4. Provide you with interactive and publishing services
When you use Zhishang Technology Services, upload and/or post information, and engage in related activities (such as posting posts, replying to posts, topping posts, liking articles, posting talks, sharing, bookmarking, and tipping), we will collect the information you upload, post, or form, and have the right to display your nickname, avatar, and posted content.
5. Assist you in placing an order, making payment, and delivering goods or services to you
(1) When you place an order for a specific product and/or service in Zhishang Technology Services, we will generate an order for you to purchase that product and/or service through the system. During the ordering process, you are required to provide at least the recipient's personal identification information, name, shipping address, postal code, recipient, contact phone number, and payment status information. If you refuse to provide such information, we will not be able to complete the relevant delivery services. If you order goods or services for others through the use of digital technology services, you need to provide the aforementioned information of the actual purchaser. Before providing us with the aforementioned information of the actual purchaser, you need to ensure that you have obtained their authorized consent;
(2) To display the order information of your account, we will collect the order information generated during your use of Zhishang Technology services (such as the product or service information you purchased, specific order number, order creation time, transaction amount) for displaying to you and facilitating your order management;
(3) To complete order payments, deliver goods or services, confirm transaction status, and provide after-sales and dispute resolution services to you, we will collect your account, order, transaction, payment, and logistics information related to the transaction progress through the trading partner, payment institution, logistics company, etc. selected by you based on the exchange, or share your transaction information with the above service providers.
6. Provide you with customer service or other user response functions
When you contact our customer service or use other user response functions (such as submitting after-sales applications, personal information protection complaints or suggestions, other customer complaints and demands), we may require you to provide necessary personal information to match and verify your user identity in order to ensure the security of your account and system. We may also keep your contact information (the other contact information you used when contacting us or provided to us voluntarily), your communication/call records and content with us, and other necessary information related to your needs, in order to contact you or assist you in resolving issues, or record the solutions and results of related issues.
7. We collect your personal information indirectly:
We may obtain relevant information authorized to be shared by you from affiliated parties and third-party partners. For example, we may obtain your authorized shared account information (including username, avatar, nickname) from a third party and bind your third-party account with your finger on technology service account after you agree to this policy, so that you can directly log in and use finger on technology services through the third-party account. We will collect and use your information in accordance with relevant laws and regulations, and based on agreements with related parties or third-party partners, and on the premise that we are confident that the information provided by them is from a legitimate source.
8. Provide you with information display and push of goods or services
(1) Show and push products or services to you
Based on the information you provide us, the information we may collect, and the information we indirectly collect about you (such as your browsing and search history, device information, location information, order information), we may conduct recommendation algorithm modeling, programmatic advertising recommendation algorithm modeling, user behavior analysis, and user profiling based on a combination of one or more of the above information, in order to extract your browsing, search preferences, behavior habits, and location information related features, in order to provide you with page displays and personalized content recommendations that better meet your needs.
We may also send marketing messages to you via email, SMS, or other means based on feature tags, providing or promoting our or third-party products and services as follows:
Our goods and services, including but not limited to: instant messaging services, online media services, interactive entertainment services, social network services, payment services, Internet search services, location and map services, applications and services, data management software and services, online advertising services, Internet finance and other social media, entertainment, online games, e-commerce, information and communication software and services;reach
Third party goods and services, including but not limited to: Internet services, food and catering, sports, music, movies, television, live performances and other arts and entertainment, books, magazines and other publications, clothing and accessories, jewelry, cosmetics, personal health and hygiene, electronics, collectibles, household utensils, appliances, home decoration and furnishings, pets, cars, hotels, transportation and tourism, banking, insurance and financial services, points and incentive plans, and other goods and services that we think may be related to you.
(2) Send you a notification
We may send you notifications related to the service when necessary (such as when we suspend, change, or terminate the provision of a particular service due to system maintenance).
If you do not wish to continue receiving our push messages, you can request us to stop pushing, for example, by following the SMS unsubscribe guidelines to stop sending promotional messages, or by setting up your mobile device to no longer receive our push messages; Except for situations where we send messages in accordance with legal regulations or service agreements for individual services.
9. To provide you with security protection
In order to improve the security of your use of our and our partners' services, protect your or other users' or the public's personal and property safety from infringement, better prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions and other security risks, and more accurately identify violations of laws and regulations or related agreement rules of technology services, we may collect, use or integrate your account information, transaction information, device information, log information, and information obtained by our affiliated companies and partners with your authorization or shared in accordance with the law to comprehensively judge your account and transaction risks, conduct identity verification, detection and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.
10. Improve our services
We may use the information collected through a certain technology service for our other services. For example, the information collected from you when using a certain digital technology service may be used in another digital technology service to provide you with specific content or display information related to you that is not commonly pushed; We may allow you to participate in surveys related to digital technology services to help us improve existing services or design new services; Meanwhile, we may use your information for software updates.
11. Other uses
You understand and agree that after collecting your personal information, we may use technical means to de identify the data, and the de identified information will not be able to identify your identity. In this case, we have the right to use the de identified information to analyze and commercialize the user database without obtaining your consent separately.
Please note that if we want to use your personal information for purposes not specified in this policy or collect additional personal information not mentioned, we will obtain your consent separately through page prompts, interaction processes, website announcements, or other means. Once you agree, such additional uses will be considered part of this policy, and such additional information will also be subject to this policy.
12. You understand and agree that some individual services may require you to grant specific access permissions on your device to enable the collection and use of information related to these permissions. For example:
(1) After you have enabled the album and/or camera permissions, you can upload and take photos/images/videos, publish information and comments, live stream videos, or communicate with customer service to provide proof;
(2) After you enable the address book permission, we can obtain your contact information in order to provide you with functions such as friend status inquiry, inviting your friends to use finger on technology services, and sharing content/products with people you know;
(3) After you enable the microphone and related voice permissions, you can use the voice function to interact with our products, others for information, or contact customer service;
(4) After you enable location permission, we can obtain your location information for you to interact with nearby friends or push personalized content to you;
(5) After you grant us the permission to read/write to your calendar, we can retrieve your schedule time to provide you with recording, reminders, and other functions.
When you need to disable these feature permissions, most mobile devices will support your request. Please refer to or contact the service provider or manufacturer of your mobile device for specific methods. Please note that by granting any permission, you authorize us to collect and use relevant information to provide you with corresponding services. Once you close any permission, it means that you have cancelled the authorization. We will no longer continue to collect and use relevant information based on the corresponding permission, nor will we be able to provide you with the services corresponding to that permission. However, your decision to disable permissions will not affect the information collection and use previously conducted based on your authorization.
13. Exceptions to obtaining authorization and consent
According to relevant laws and regulations, collecting your information in the following situations does not require your authorization and consent:
(1) Related to national security and defense security;
(2) Related to public safety, public health, and major public interests;
(3) Related to criminal investigation, prosecution, trial, and execution of judgments;
(4) For the purpose of safeguarding the significant legitimate rights and interests of the information subject or other individuals, such as life and property, but it is difficult to obtain your consent;
(5) The information collected is self disclosed by you to the public;
(6) Collecting information from legally disclosed sources, such as legitimate news reports, government information disclosure, and other channels;
(7) Necessary to sign the contract according to your requirements;
(8) Used to maintain the safe and stable operation of digital technology services, such as discovering and handling product or service failures;
(9) Necessary for legitimate news reporting;
(10) Academic research institutions conduct statistical or academic research necessary for the public interest, and when providing results of academic research or descriptions to external parties, they de identify the information contained in the results;
(11) Other circumstances stipulated by laws and regulations.
14. Tips on Personal Sensitive Information
The information provided by you or collected by us above may include your personal sensitive information, such as ID number, personal biometric information, bank account number, communication records and content, property information, credit information, whereabouts, accommodation information, health and physiological information, and transaction information. Please be cautious and pay attention to personal sensitive information. You agree that we may process your personal sensitive information in accordance with the purposes and methods described in this policy.
2、 How do we use cookies or similar technologies
We or our third-party partners may obtain and use your information through cookies or similar technologies, and store such information as log information.
By using COOKIES, we provide users with a simple and personalized online experience. A cookie is a small amount of data that is sent from a web server to your browser and stored on your computer's hard drive. We use cookies to benefit their users. For example, to make the login process to the virtual community of Zhishang Technology faster, you can choose to store your username in a COOKIES. This way, it will be more convenient and efficient for you to log in to the services of Zhishang Technology next time. COOKIES can help us determine the pages and content you are connecting to, the time you spend on specific finger pointing technology services, and the finger pointing technology services you choose.
COOKIES enable us to serve you better and faster, and make your experience in digital technology services more personalized. However, you should be able to control whether and how cookies are accepted by your browser. Please refer to the file attached to your browser for more information on this matter.
We and third-party partners may collect and use your information through cookies or similar technologies, and store such information.
We use our own cookies or similar technologies, which may be used for the following purposes:
1. Remember your identity. For example, cookies or similar technologies help us identify you as our registered user, or store information you provide us about your preferences or other information;
2. Analyze your usage of our services. We can use COOKIES or similar technologies to understand what activities you are using Zhishang Technology services for, or which services are most popular;
3. Advertising optimization. COOKIES or similar technologies help us provide you with relevant advertisements based on your information, rather than conducting general advertising campaigns.
While using COOKIES or similar technologies for the above purposes, we may aggregate non personally identifiable information collected through COOKIES or similar technologies and provide it to advertisers and other partners for analysis of how you and other users use digital technology services and for advertising purposes.
There may be cookies or similar technologies placed by advertisers and other partners on technology services. These cookies and/or similar technologies may collect non personally identifiable information related to you for the purpose of analyzing how users use such services, sending you advertisements that may interest you, or evaluating the effectiveness of advertising services. These third-party cookies or similar technologies that collect and use such information are not subject to this policy, but are subject to their own information protection statements, and we are not responsible for third-party cookies or similar technologies.
You can refuse or manage cookies or similar technologies through browser or user selection mechanisms. But please note that if you disable COOKIES or similar technologies, we may not be able to provide you with the best service experience, and some services may not function properly. Meanwhile, you will still receive advertisements, but their relevance to you will decrease.
3、 Personal information that we may share, transfer or disclose
（1） Share
We will not share your personal information with any third party other than Zhishang Technology without your consent, except in the following circumstances:
1. We offer our services to you. We may share your information with our partners and other third parties to enable the functionality of Zhishang Technology Services and enable you to use the services you need normally, such as payment institutions that provide payment services, merchants who join Zhishang Technology Platform, partners who provide data services (including network advertising monitoring, data statistics, and data analysis), and third-party logistics companies;
2. Necessary sharing with related parties. In order for us to provide you with consistent services based on a unified account system, as well as for you to manage, personalize recommendations, ensure system and account security, etc., your personal information may be necessary shared between us and our affiliates;
3. To achieve the purpose described in the first article of this policy, "How We Collect and Use Personal Information";
4. Fulfill our obligations and exercise our rights under this policy or other agreements we have reached with you;
5. The purpose of sharing with third parties such as partners who entrust us with promotion is to enable them to understand the coverage and effectiveness of the promotion. For example, we can inform the client how many people have viewed their promotional information or purchased the client's products after seeing this information, or provide them with non personally identifiable statistical information to help them understand their audience or customers;
6. Within the scope permitted by laws and regulations, we may exchange information with other companies and organizations in order to comply with the law, safeguard the interests, property or safety of us and our affiliates or partners, you or other technology users, or the public, such as to prevent illegal activities such as fraud and reduce credit risks. However, this does not include information sold, rented, shared, or otherwise disclosed for profit in violation of the commitments made in this policy;
7. According to your legitimate needs or with your authorized consent;
8. Provide your information at the lawful request of your guardian;
9. Provided in accordance with the individual service agreement (including electronic agreements signed online and corresponding platform rules) or other legal documents agreed upon with you;
10. Provided based on academic research;
11. Provided based on social public interests that comply with laws and regulations.
We will only share your personal information for lawful, legitimate, necessary, specific, and clear purposes. We will sign strict confidentiality agreements with companies, organizations, and individuals with whom we share personal information, requiring them to handle the information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures.
（2） Transfer
1. As our business continues to grow, we may engage in mergers, acquisitions, asset transfers, or similar transactions, and your information may be transferred as part of such transactions. We will require new companies or organizations that hold your personal information to continue to be bound by this policy. Otherwise, we will require the company or organization to seek your authorization and consent again.
2. After obtaining your explicit consent, we will transfer your personal information to other parties.
（3） Disclosure
We will only disclose your personal information under the following circumstances and with industry standard security measures in place:
1. According to your needs, disclose the information you have specified in the disclosure method that you have explicitly agreed to;
2. We may disclose your information based on the type and disclosure method required by laws, regulations, mandatory administrative law enforcement, or judicial requirements. Subject to compliance with laws and regulations, when we receive a request for disclosure of the aforementioned information, we will require the recipient to provide corresponding legal documents, such as subpoenas or investigation letters. We firmly believe that the information requested from us should be kept as transparent as possible within the limits permitted by law. We have carefully reviewed all requests to ensure that they have legal basis and are limited to data obtained by law enforcement agencies for specific investigation purposes and with legitimate rights.
（4） Exceptions to obtaining prior authorization and consent for sharing, transferring, or disclosing information
In the following situations, sharing, transferring, or disclosing your information does not require your prior authorization and consent:
1. Related to national security and defense security;
2. Related to public safety, public health, and major public interests;
3. Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and execution of judgments;
4. For the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as life and property, but it is difficult to obtain my consent;
5. Information that you disclose to the public on your own;
6. Collecting information from legally disclosed sources, such as legitimate news reports, government information disclosure, and other channels.
According to legal provisions, sharing, transferring, and disclosing personal information that has undergone de identification processing, and ensuring that the data recipient cannot recover and re identify the information subject, does not constitute external sharing, transfer, or public disclosure of personal information. The storage and processing of such data will not require separate notification to you and your consent.
4、 How do we store and protect personal information
We only store your personal information for the period necessary for the purposes stated in this policy and for the shortest period required by laws and regulations. If we terminate our services or operations, we will promptly cease the activity of collecting your personal information. At the same time, we will comply with relevant laws and regulations and notify you in advance. After terminating our services or operations, we will delete or anonymize your personal information, except as otherwise provided by laws, regulations or regulatory authorities.
The personal information collected and generated during our operations within the territory of the People's Republic of China is stored within China, except in the following circumstances:
1. There are clear provisions in laws and regulations;
2. Obtain your authorization and consent;
3. The services you are using on Zhishang Technology involve cross-border transactions, and Zhishang Technology needs to provide your personal information overseas.
In response to the above situation, we will ensure that your personal information is adequately protected in accordance with this policy and national laws and regulations.
We attach great importance to information security and have established a dedicated security team to take all reasonable and feasible measures to protect your personal information
（1） Data security technical measures
We will adopt security measures that comply with industry standards, including establishing reasonable institutional norms and security technologies to prevent unauthorized access, use, and modification of your personal information, and to avoid data damage or loss.
Our service adopts various encryption technologies. For example, in some digital technology services, we will use encryption technology (such as SSL) to protect your personal information, encrypt and store your personal information, and isolate it through isolation technology.
When using personal information, such as information display and information association calculation, we will use various data anonymization techniques to enhance the security of information during use.
We will also adopt strict data access control and multi factor authentication technology to protect personal information and prevent data from being used in violation of regulations.
（2） Other security measures we take to protect personal information
We manage and standardize the storage and use of personal information by establishing a data classification and grading system, data security management standards, and data security development standards.
We implement comprehensive security controls on data through confidentiality agreements for information contacts, monitoring and auditing mechanisms. We will also hold security and privacy protection training courses to enhance employees' awareness of security and the importance of protecting information.
（3） We only allow IT employees and partners who need to know this information to access your personal information, and have established strict access control and monitoring mechanisms for this purpose. We also require all personnel who may have access to your personal information to fulfill corresponding confidentiality obligations. If these obligations are not fulfilled, legal responsibility may be pursued or cooperation with Zhishang Technology may be suspended.
（4） We will take all reasonable and feasible measures to ensure that unrelated personal information is not collected.
（5） The Internet is not an absolutely secure environment, and the way of communication with other users such as e-mail, instant messaging, social software or other service software cannot be determined whether it is fully encrypted. We recommend that you use complex passwords when using such tools, and pay attention to protecting your information security.
（6） The Internet environment is not 100% secure. We will try our best to ensure or guarantee the security of the personal information you send us. If our physical, technological, or management protective facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of personal information, which damages your legitimate rights and interests, we will bear corresponding legal responsibilities.
（7） Security incident handling
When communicating with third parties or purchasing goods and services through digital technology services, you inevitably need to disclose your information, such as contact information or postal address, to the counterparty or potential counterparty. Please protect your information properly and only provide it to others when necessary.
To address the potential risks of personal information leakage, damage, and loss, we have established multiple systems that clarify the classification and grading standards for security incidents and vulnerabilities, as well as corresponding processing procedures. We have also established a dedicated emergency response team for security incidents. In accordance with the requirements of security incident handling standards, we have activated security plans for different security incidents, conducted stop loss, analysis, positioning, formulated remedial measures, and collaborated with relevant departments to trace and crack down on them.
After an unfortunate information security incident occurs, we will promptly inform you of 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 remedial measures for you in accordance with legal requirements. We will also promptly inform you of the relevant information of the event through email, letter, phone, push notifications, and other means. If it is difficult to inform the information subject one by one, we will adopt a reasonable and effective way to publish an announcement. At the same time, we will proactively report the handling of information security incidents in accordance with regulatory requirements.
Please understand that due to technological limitations and risk prevention limitations, even if we have tried our best to strengthen security measures, we cannot always guarantee 100% information security. You need to understand that the system and communication network you use to access the technology services on Zhishang may encounter problems due to situations beyond our control.
Please make sure to properly safeguard your account, password, and other identity elements. When you use Zhishang Technology services, we will identify your identity through your account, password, and other identity elements. Once you disclose the aforementioned information, you may suffer losses and may have adverse effects on you. If you find that your account, password, and/or other identity elements may or have been leaked, please contact us immediately so that we can take appropriate measures in a timely manner to avoid or reduce related losses.
5、 How to manage your personal information
（1） Access, update, and delete
We encourage you to update and modify your personal information to make it more accurate and effective. You can access your personal information through digital technology services and complete or request us to modify, supplement, and delete it according to the corresponding information management method. We will use appropriate technical means or provide contact channels for submitting applications to ensure that you can access, update, and correct your personal information or other information provided when using the technology services on Zhishang as much as possible.
When accessing, updating, correcting, and deleting the aforementioned information, we may require you to verify your identity to ensure information security. For the information collected from you through COOKIES or similar technologies, we also explain the selection mechanism provided to you in the second section of this policy, "How We Use COOKIES or Similar Technologies". If you want to query, modify or delete some of your information, please log in to the Technology Account Center (reg.163. com) or follow the specific instructions for individual services.
Unless otherwise stipulated by laws and regulations, when you correct or delete your personal information or apply to cancel your account, we may not immediately correct or delete the corresponding information from the backup system, but we will correct or delete this information when the backup is updated.
（2） Public and Sharing
Our multiple services allow you to publicly share your relevant information not only with your social network, but also with all users who use the service, such as the information you upload or post on the Finger Tech service, your responses to information uploaded or posted by others, uploading or posting your information via email or in public areas visible to unspecified users on the Finger Tech service, as well as location data and log information related to this information. As long as you do not delete the information you have publicly or shared, the relevant information may remain in the public domain; Even if you delete shared information, the information may still be independently cached, copied, or stored by other users or third parties beyond our control, or kept in the public domain by other users or such third parties. If you disclose or share information through the above channels, resulting in the leakage of your information, we will not be held responsible. Therefore, we remind and ask you to carefully consider whether to disclose or share your information through the above channels.
（3） Cancel
Under the conditions stipulated in the service agreement for a single service provided by Zhishang Technology and relevant national laws and regulations, your Zhishang Technology service account may be cancelled or deleted. After the account is cancelled or deleted, all service materials and data related to the account under the single service item will be deleted or processed in accordance with the service agreement of the single service, except as otherwise provided by laws and regulations.
（4） Change the scope of your authorized consent
You can always choose whether to disclose information. Some information is necessary for the use of digital technology services, but the provision of most other information is up to you to decide. You can change the scope of your authorization for us to continue collecting information or revoke your authorization by deleting information, disabling device functions, and other means.
After you revoke your authorization, we are unable to continue providing you with the services corresponding to the revocation of authorization, and we will no longer process your corresponding information. But your decision to revoke authorization will not affect the information processing previously carried out based on your authorization.
6、 Third party services
Technology services may be integrated or linked to social media or other services provided by third parties (including websites or other forms of services). include:
1. You can use the "Share" button to share certain content of your digital technology services with third-party services, or you can share third-party service content with your digital technology services. These features may collect your information (including your log information) and may install cookies on your computer to enable the normal operation of the aforementioned functions;
2. We provide you with links through advertising or other means of our services, allowing you to link to third-party services or websites; reach
3. Other situations of accessing third-party services. For example, in order to achieve the purposes stated in this policy, we may access SDKs or other similar applications provided by third-party service providers and share some of the information we collect about you in accordance with this policy with such third-party service providers in order to provide better customer service and user experience. At present, the third-party service providers we access mainly include the following types:
(1) Used for advertising related services, including advertising display, advertising data monitoring/statistics, etc;
(2) Used for message push functions, including push notifications from mobile phone manufacturers, specific event reminders, personalized content recommendations, etc;
(3) Used for payment related services, including order payment, transaction behavior verification, income settlement, payment information summary and statistics, etc;
(4) Used to obtain device location permissions, collect device information and log information with your consent;
(5) Used for third-party authorization services, including third-party account login, sharing relevant content to third-party products, etc;
(6) Used to support product functional modules, including online live streaming, video playback, voice recognition AR、 Intelligent customer service, bullet screen playback, content storage, etc;
(7) Used to optimize product performance, including improving hardware distribution capabilities, reducing server costs, and performing functional hot repairs;
(8) Used for account security, product reinforcement related services, including network monitoring, domain name resolution (HTTPDNS), anti hijacking, anti spam and anti cheating, encryption and decryption services, etc.
We will only share your information for legitimate, necessary, and specific purposes. We will require third-party service providers with whom we share information to fulfill relevant confidentiality obligations and take corresponding security measures.
These third-party social media or other services are operated by the relevant third parties. Your use of such third-party social media services or other services (including any information you provide to such third parties) is subject to the third party's own terms of service and information protection statement (not this policy), and you need to carefully read their terms. This policy only applies to the personal information we collect and does not apply to any third-party services or information usage rules provided by third parties. If you find that these third-party social media or other services pose risks, we recommend that you terminate the relevant operations to protect your legitimate rights and interests.
7、 Protection of Minors
We suggest that any minors participating in online activities should obtain the consent of their parents or other guardians (hereinafter referred to as "guardians") in advance. We will protect the relevant information of minors in accordance with relevant national laws and regulations.
We encourage guardians to guide minors in using digital technology services. If you are a minor under the age of fourteen, please notify your guardian to read and accept our "Zhishang Technology Children's Personal Information Protection Rules and Guardian Notice" together, and seek their consent and guidance before using Zhishang Technology services or submitting personal information.
8、 Notification and Revision
In order to provide you with better services, we may modify the terms of this policy in a timely manner based on the updates of our technology services and relevant legal requirements. Such modifications constitute a part of this policy. If such updates result in a substantial reduction or significant change in your rights under this policy, we will notify you through website announcements, push notifications, pop-up prompts, or other means before this policy takes effect. If you do not agree with such changes, you may choose to stop using the digital technology services; If you continue to use Zhishang Technology Services, it means that you have fully read, understood, and agreed to be bound by the revised policy.
Any modifications we make will prioritize your satisfaction. We encourage you to review our privacy policy every time you use our digital technology services.
We may issue service related announcements when necessary, such as when we suspend a service due to system maintenance. You may not be able to cancel these service related announcements that are not promotional in nature.
9、 How to contact us
We have established a dedicated department for personal information protection, which will protect your personal information in accordance with this policy. If you have any complaints or reports about network information security, or if you have any questions, opinions or suggestions regarding this policy, the privacy measures of Zhishang Technology, or related matters of your information, please contact the personal information protection staff of Zhishang Technology. You can send an email to
Privacy@service.netease.com Or write to the following address: Personal Information Protection Specialist, Zhishang Technology Phase II, No. 399 Wangshang Road, Binjiang District, Hangzhou City (recipient); Postal code: 310052.
Generally, we will respond within fifteen days after receiving your questions, opinions, or suggestions and verifying your user identity.
Attachment 1:
Privacy Protection and Personal Information Utilization Policy for Online Game Users
[Attention] In order to protect the privacy rights of online game users (hereinafter referred to as "users") and regulate the use of personal information of online game users, this policy is formulated. Please carefully read all the following content (especially the bold and underlined content). If users do not agree with any content of this policy, please do not register or use Zhishang Technology Services. If the user enters the registration process, it means that the user has reached an agreement with Zhishang Technology and voluntarily accepts all the contents of this policy. Afterwards, users shall not make any form of defense based on the content of this policy that they have not read.
Respecting users' personal privacy is a fundamental policy of technology. Privacy "refers to the personal identity information provided by users to Zhishang Technology when registering for a Zhishang Technology email account, including but not limited to the name, valid personal identification number, contact information, home address, etc. in the user's registration information. Zhishang Technology has always actively taken reasonable measures such as technology and management to ensure the security and effectiveness of user accounts; Zhishang Technology will use the collected information in good faith, take effective and necessary measures to protect your privacy and security, and use commercially reasonable security technology measures to protect your privacy from unauthorized access, use, or disclosure.
Due to business needs, Zhishang Technology needs to share user registration information with its affiliated companies (including but not limited to Guangzhou Zhishang Technology Computer System Co., Ltd., Hangzhou Zhishang Technology Thunder Fire Technology Co., Ltd., Zhishang Technology (Hangzhou) Network Co., Ltd., Zhishang Technology Treasure Co., Ltd., Beijing Zhishang Technology Youdao Computer System Co., Ltd., Zhishang Technology Youdao Information Technology (Beijing) Co., Ltd., etc.). Zhishang Technology and the above-mentioned affiliated companies promise to use user information in good faith, and Zhishang Technology will not disclose or share personal identity information such as name, valid personal identification number, contact information, home address, etc. in user registration information to any party other than the above-mentioned affiliated companies, except for the following situations: The sentence is:
(1) Authorization from the user or user guardian refers to the disclosure of technology on the platform;
(2) Legal requirements refer to technology disclosure;
(3) Judicial or administrative authorities refer to technology provided based on legal procedural requirements;
(4) When Shangshi Technology files a lawsuit or arbitration against users to protect its legitimate rights and interests;
(5) When providing the user's personal identity information upon the legal request of the user's guardian.
Special reminder: This policy only applies to users who use Zhishang Technology's online gaming services. In case of any inconsistency between this policy and similar terms in the "Zhishang Technology Email Account Service Terms" and "Zhishang Technology Group Privacy Policy", the provisions of this policy shall prevail.
Attachment 2:
Guidelines for the Protection of Personal Information of Children in Technology and Notice for Guardians
Zhishang Technology Group and its affiliated companies (hereinafter referred to as "Zhishang Technology" or "we") are well aware of the importance of personal information and privacy security for children (referring to minors under the age of fourteen, the same below). We hope to explain the corresponding processing rules and related matters when collecting and using children's personal information through the "Zhishang Technology Children's Personal Information Protection Rules and Guardian Notice" (hereinafter referred to as "this policy"). Before using our various products and services (hereinafter referred to as "technology services"), children, their parents, or other guardians (hereinafter referred to as "guardians") must carefully read and thoroughly understand this policy, especially the terms marked in bold/underline. After confirming full understanding and agreement to all terms, they can start using it.
Special instructions from the guardian:
If we learn that your child is under the age of fourteen, we will take special measures in accordance with this policy to protect the personal information we obtain about your child. Please help us protect your child's personal information and privacy security by requiring them to read and accept this policy together under your supervision, and to use digital technology services and submit personal information with your consent and guidance. If you do not agree with the content of this policy, it may result in the malfunction of the Finger Up Technology Services or the inability to achieve the intended service effect. You should request your child to immediately stop accessing/using the Finger Up Technology Services. By clicking on 'Agree to this Policy' online, or by allowing your child to use/continue using digital technology services or submit personal information, you agree to our collection, use, storage, sharing, transfer, and disclosure of your child's personal information in accordance with this Policy (including updated versions).
Special instructions for children:
We suggest that any child participating in online activities should obtain the consent of their guardian in advance. If you are a child, please notify your guardian to read this policy together and seek their consent and guidance before using digital services or submitting personal information. By clicking on 'Agree to this Policy' online, or by using/continuing to use Zhishang Technology Services and submitting personal information, you indicate that you have obtained permission from your guardian. Your guardian agrees that we will collect, use, store, share, transfer, and disclose your personal information in accordance with this Policy (including updated versions).
This policy applies to our activities of collecting, using, storing, sharing, transferring, and disclosing children's personal information through the internet within the territory of the People's Republic of China. When a child uses any digital technology service, the guardian agrees to accept the protection of this policy and the specific child personal information protection rules and terms (if any, hereinafter referred to as "specific terms") issued by us in that particular service. In this case, the specific terms and the terms of this policy shall be effective for both the guardian and the child. If there is any inconsistency between specific terms and the terms of this policy, the specific terms shall prevail within the scope of the specific terms. If a single service we provide is not applicable to this policy, the service will explicitly exclude the application of this policy in an appropriate manner. In terms of the rules for protecting children's personal information, if there is any inconsistency between this policy and the main text of the Privacy Policy of Zhishang Technology Group, this policy shall prevail. If there is no mention in this policy, the Privacy Policy of Zhishang Technology Group shall prevail.
After reading this policy, if you have any questions about this policy or matters related to this policy, you can contact us through the feedback channels listed in the "How to Contact Us" section of this policy, and we will provide answers as soon as possible.
catalogue
1、 How do we collect and use children's personal information
2、 Children's personal information that we may share, transfer or disclose
3、 How do we store and protect children's personal information
4、 How to manage children's personal information
5、 Third party services
6、 Revision of this policy
7、 How to contact us
1、 How do we collect and use children's personal information
（1） We will strictly fulfill our obligations and responsibilities for protecting children's personal information as stipulated by laws and regulations, and follow the principles of legitimate necessity, informed consent, clear purpose, security protection, and lawful use. After obtaining the consent of our guardians, we will collect and use children's personal information:
1. In some individual services, we may require users to fill in personal birthday information or identify whether the user is a child based on the identity information filled in by the user. According to laws and regulations, children are only allowed to continue using relevant digital technology services after obtaining the consent of their guardians.
2. When we identify the user as a child, we may collect the contact information of the guardian (such as phone number, email) and contact the guardian to verify their guardianship relationship with the child. In order to better protect the rights and interests of children, we may also collect more information from guardians (such as name, ID card, household registration book, or other proof of guardianship relationship) to further verify the guardianship relationship between guardians and children.
3. In the process of children using digital technology services, we may also collect and use other personal information of children. Please refer to the "How We Collect and Use Personal Information" section of the "Digital Technology Group Privacy Policy" for detailed information. If we need to collect and use children's personal information beyond the above scope, we will obtain the consent of the guardian again.
（2） Exceptions to obtaining authorization and consent
According to relevant laws and regulations, collecting information from children in the following situations does not require authorization or consent from the child and/or guardian:
(1) Related to national security, defense security, public safety, public health, and major public interests;
(2) Related to criminal investigation, prosecution, trial, and execution of judgments;
(3) For the purpose of safeguarding the significant legitimate rights and interests of the information subject or other individuals, such as life and property, but it is difficult to obtain the consent of the guardian themselves;
(4) The information collected is publicly disclosed by children or guardians themselves to the general public;
(5) Collecting information from legally disclosed sources, such as legitimate news reports, government information disclosure, and other channels;
(6) Necessary to sign a contract at the request of the guardian;
(7) Necessary for maintaining the safe and stable operation of digital technology services, such as detecting and handling malfunctions in digital technology services;
(8) Automatically retaining and processing information through computer information systems without identifying that the retained and processed information belongs to children's personal information;
(9) Academic research institutions conduct statistical or academic research necessary for the public interest, and when providing results of academic research or descriptions to external parties, they de identify the information contained in the results;
(10) Other circumstances stipulated by laws and regulations.
（3） Tips on sensitive personal information of children
The child information provided by children or guardians or collected by us may include sensitive personal information of children, such as ID numbers, personal biometric information, bank accounts, communication records and content, property information, credit information, whereabouts, accommodation information, health and physiological information, and transaction information. Guardians and children are advised to be cautious and pay attention to sensitive personal information of children. Guardians agree that we may handle sensitive personal information of children in accordance with the purposes and methods described in this policy.
2、 Children's personal information that we may share, transfer or disclose
（1） Share
We will not share children's personal information with any third party other than Zhishang Technology without the consent of the guardian, except in the following circumstances:
1. Provide our services to children. We may share children's information with partners and other third parties to achieve the functionality of digital technology services and enable children to use the services they need normally, such as payment institutions that provide payment services, merchants who join digital technology platforms, partners who provide data services (including online advertising monitoring, data statistics, and data analysis), third-party logistics companies, and other service providers;
2. Necessary sharing with related parties. In order to facilitate our provision of consistent services to children based on a unified account system, as well as to facilitate their unified management, personalized recommendations, system and account security, children's personal information may be necessary shared between us and our affiliates;
3. To achieve the purpose stated in the first article of this policy, "How We Collect and Use Children's Personal Information";
4. Fulfill our obligations and exercise our rights under this policy or other agreements we have reached with children or guardians;
5. The purpose of sharing with third parties such as partners who entrust us with promotion is to enable them to understand the coverage and effectiveness of the promotion. For example, we can inform the client how many people have viewed their promotional information or purchased the client's products after seeing this information, or provide them with statistical information that cannot identify the child's personal identity to help them understand their audience or customers;
6. Within the scope permitted by laws and regulations, we may exchange information with other companies and organizations in order to comply with the law, safeguard the interests, property, or safety of us, our affiliates or partners, children, guardians, or other technology users or the general public, such as to prevent illegal activities such as fraud and reduce credit risks. However, this does not include information sold, rented, shared, or otherwise disclosed for profit in violation of the commitments made in this policy;
7. According to the legitimate needs of the child or with the authorization and consent of the guardian;
8. At the legal request of the guardian;
9. Provided in accordance with individual service agreements (including electronic agreements signed online and corresponding platform rules) or other legal documents;
10. Provided based on social and public interests that comply with laws and regulations.
We will only share children's personal information for legal, legitimate, necessary, specific, and clear purposes. We conduct security assessments and sign strict confidentiality agreements with companies, organizations, and individuals with whom we share personal information, requiring them to handle information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures.
（2） Transfer
1. As our business continues to grow, we may engage in mergers, acquisitions, asset transfers, or similar transactions, and children's information may be transferred as part of such transactions. We will conduct a security assessment and require new companies or organizations that hold children's personal information to continue to be bound by this policy. Otherwise, we will require the company or organization to seek authorization and consent from the guardian again.
2. After obtaining the consent of the guardian, we will transfer the child's personal information to other parties.
（3） Disclosure
We will only disclose children's personal information under the following circumstances and with industry standard security measures in place:
1. According to the needs of the child or guardian, disclose the information designated by them in a manner agreed upon by the guardian;
2. We may disclose children's information based on the type and disclosure method required by laws, regulations, mandatory administrative law enforcement, or judicial requirements. Subject to compliance with laws and regulations, when we receive a request for disclosure of the aforementioned information, we will require the recipient to provide corresponding legal documents, such as subpoenas or investigation letters. We firmly believe that the information requested from us should be kept as transparent as possible within the limits permitted by law. We have carefully reviewed all requests to ensure that they have legal basis and are limited to data obtained by law enforcement agencies for specific investigation purposes and with legitimate rights.
（4） Exceptions to obtaining prior authorization and consent for sharing, transferring, or disclosing information
In the following situations, sharing, transferring, or disclosing children's information does not require prior authorization and consent from the guardian:
1. Related to national security and defense security;
2. Related to public safety, public health, and major public interests;
3. Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and execution of judgments;
4. For the purpose of safeguarding the significant legitimate rights and interests of children or other individuals, such as life and property, but it is difficult to obtain the consent of the guardian;
5. Information disclosed by children or guardians to the public on their own;
6. Collecting information from legally disclosed sources, such as legitimate news reports, government information disclosure, and other channels.
According to legal provisions, sharing, transferring, and disclosing personal information that has undergone de identification processing, and ensuring that the data recipient cannot recover and re identify the information subject, does not constitute external sharing, transfer, or public disclosure of personal information. The storage and processing of such data will not require separate notification to the guardian and obtaining their consent.
（1） We only store children's personal information for the period necessary for the purposes stated in this policy and for the shortest period required by laws and regulations. If we terminate our services or operations, we will promptly cease the collection of children's personal information and comply with relevant laws and regulations to notify guardians in advance. After terminating our services or operations, we will delete or anonymize children's personal information, except as otherwise provided by laws, regulations or regulatory authorities.
（2） We attach great importance to the privacy and security of children, have established a dedicated security team, and take all reasonable and feasible measures to protect children's personal information:
We will adopt encryption and other technical measures to store children's personal information and ensure information security. At the same time, we strictly set information access permissions for our staff based on the principle of minimum authorization, and control the scope of children's personal information access; Staff accessing children's personal information must obtain approval from the person in charge of protecting children's personal information or authorized management personnel, record the access situation, and take technical measures to avoid illegal copying and downloading of children's personal information. If we discover that a child's personal information has been or may be leaked, damaged, or lost, we will immediately activate the emergency plan, take remedial measures, and inform the affected guardians and children of the relevant situation through email, letter, phone, push notifications, announcements, and other means.
If you would like to learn more, please refer to the "How We Store and Protect Personal Information" section of the "Zhishang Technology Group Privacy Policy" for a detailed understanding of how we store and protect children's personal information.
Due to technological limitations and risk prevention limitations, even if we have tried our best to strengthen security measures, we cannot always guarantee 100% information security. Guardians need to understand that the systems and communication networks used for children's access to technology services may encounter problems due to situations beyond our control.
Please ensure that guardians and children properly keep their digital service accounts, passwords, and other identity elements. When children use digital technology services, we identify their identity through their account, password, and other identification elements. Once guardians and children disclose the aforementioned information, they may suffer losses and may have adverse effects on themselves. If guardians and children discover that their accounts, passwords, and/or other identity elements may or have been leaked, please contact us immediately so that we can take appropriate measures in a timely manner to avoid or reduce related losses.
4、 How to manage children's personal information
During the period when children use digital technology services, we will take appropriate actions to set up, guide, or provide the contact channels listed in the "How to Contact Us" section of this policy in our individual services, to ensure that guardians and children can access, correct, delete children's personal information, and cancel children's registered accounts as much as possible. When accessing, correcting, deleting the aforementioned information or applying for account cancellation, we may require guardians and/or children to verify their identity to ensure information security. Unless otherwise stipulated by laws and regulations, when guardians and children correct or delete personal information of children or apply for account cancellation, we may not immediately correct or delete the corresponding information from the backup system, but we will correct or delete this information when the backup is updated.
（1） Accessing children's personal information
Guardians and children can view their personal information provided or generated during the use of digital technology services, such as personal information profiles, partial usage records, and published content.
（2） Correction of Children's Personal Information
We encourage guardians and children to update and modify their personal information to make it more accurate and effective. If guardians and children discover errors in the personal information we collect, use, and process, they can contact us to correct them. We will take timely measures to correct any issues after completing identity verification and validation.
（3） Delete children's personal information
According to the specific situation of the child's choice of digital technology services, guardians and children can delete some of the child's personal information on their own when using digital technology services. In the following situations, guardians and children can directly request us to delete their personal information. We will take timely measures to delete it after completing identity verification and verification issues, including:
1. We collect, store, use, transfer, or disclose children's personal information in violation of laws and regulations or agreements with guardians and children;
2. Collecting, storing, using, transferring, or disclosing personal information of children beyond the scope of the purpose or necessary period;
3. If the guardian withdraws their consent;
4. Guardians or children who terminate the use of digital technology services through cancellation or other means.
However, please note that if guardians and children delete or request us to delete specific personal information of children, it may result in the inability to continue using all or part of the digital technology services.
（4） Cancel account
Under the conditions stipulated in the service agreement and relevant laws and regulations for the single service of Zhishang Technology, we also provide the cancellation of registered accounts. Guardians and children can operate or contact us according to the specific settings and guidelines of the single service.
（5） Change the scope of authorization and consent
Guardians and children can always choose whether to disclose information. Some information is necessary for the use of digital technology services, but the provision of most other information is self determined. Guardians and children can change the scope of their authorization for us to continue collecting information or revoke their authorization by deleting information, disabling device functions, and other means.
When guardians and children revoke their authorization, we are unable to continue providing the services corresponding to the revocation of authorization and will no longer process the corresponding information. However, the decision to revoke authorization will not affect the information processing previously carried out based on the authorization of guardians and children.
5、 Third party services
Technology services may provide children with access to or links to third-party social media or other services (including websites or other forms of services). Please refer to the "Third Party Services" section of the Privacy Policy of Zhishang Technology Group for detailed information on the types of third-party services we access or link to.
6、 Revision of this policy
In order to provide better services, we may modify the terms of this policy in a timely manner based on the updates of our technology services and relevant requirements of laws and regulations. Such modifications constitute a part of this policy. If such updates result in a substantial reduction or significant change in the rights of guardians and children under this policy, we will notify them through website announcements, push notifications, pop-up prompts, or other means before this policy takes effect. If guardians do not agree with such changes, they may choose to require children to stop using digital technology services; If children continue to use digital technology services, it means that the guardian has fully read, understood, and agreed to be bound by the revised policy.
Any modifications we make will prioritize user satisfaction. We encourage guardians and children to refer to our 'Children's Personal Information Protection Rules and Guardian Notice' every time they use our digital technology services.
