Privacy Policy
Updated on August 25, 2022
Effective from September 1, 2022
Laiye Technology (hereinafter referred as “We” or “Us”) respects and protects your privacy. When you use products and services offered by Laiye Technology, we might collect, retain, use and share your personal data in accordance with this Policy, and provide you with channels to update and manage your personal data. In addition to this Policy, we also provide rules for processing personal data in specific products and services (hereinafter referred to as “Special Reminders for Privacy Policy”). You may review such Special Reminders for Privacy Policy before using those specific products and services.
This Policy is closely related to the products and services you use. You are encouraged to thoroughly read and comprehend the entire content of this Policy, and decide as you deem appropriately. We aim to express in a plain and concise manner, and have marked in bold herein the clauses that are significantly related to your rights and interests to draw your attention.
We will update this Policy and the Special Reminders for Privacy Policy from time to time, and notify you when updating. If you have any questions, please contact us via the contact information provided herein.
This Policy includes the following contents:
I. About us
II. How we define personal data
III. How we collect personal data
IV. How we use personal data
V. How we share personal data
VI. How we protect and store personal data
VII. How to exercise your rights
VIII. COOKIES
IX. Protection of minors
X. Contact us
I. About us
For the purpose of this Policy, Laiye Technology refers to and represents Beijing Laiye Network Technology Co., Ltd. and all legal entities under its control by equity or agreement, including but not limited to, Laiye Technology (Beijing) Co., Ltd., Hunan Laiye Technology Co., Ltd., Laiye Technology (Fujian) Co., Ltd., Laiye Bert (Fujian) Technology, Co., Ltd., Laiye (Zhangjiagang) Smart City Technology Co., Ltd., Shanghai Laiye Bert Network Technology Co., Ltd., Laiye Bert Technology (Shenzhen) Co., Ltd., Beijing Xiaolai Infinite Technology Co., Ltd., etc.
II. How we define personal data
All information relating to an identified or identifiable natural person (excluding anonymized information), that is being recorded electronically or otherwise, will be referred as Personal Information by Laiye Technology.
Laiye Technology may engage management and technological tools to de-identify or anonymize personal data, so that it neither can be used to identify a specific individual without additional information, nor can be used to identify a specific individual or recovered. For the avoidance of doubt, the personal data hereunder does not include de-identified or anonymized information.
III. How we collect personal data
In the process of designing and operating products, services and webpages, we aim to minimize the scope of personal data being collected. That is, generally we only collect personal data that is necessary for providing you with products, services and webpages. In the Special Reminders for Privacy Policy, we explain in detail the scope, purpose and necessity of collecting personal data for specific products, services and webpages.
When you use Laiye Technology’s products, services and websites, we may collect your personal data from yourself or through other channels. Other channels may include:
1) Other individuals. This usually happens when other individuals send you a product of Laiye Technology, invite you to participate in events of Laiye Technology, or share with you content released by Laiye Technology.
2) Partners of Laiye Technology. This usually happens when you purchase our products and services through our partners or participate in our forums or events through the guidance of our partners.
3) Other authorized channels. This usually happens when you send to Laiye Technology an instruction, authorizing Laiye Technology to collect your personal data through the channels you designated.
We will only collect and process your personal data in accordance with this Policy with your express consent except for the following circumstances. While in the following circumstances, we will perform our obligations in accordance with applicable laws and regulations without seeking for your consent.
1）Necessary for signing and performing contracts at your request;
2）Necessary to fulfill statutory obligations, such as information required by relevant laws and regulations on anti-money laundering, anti-fraud, personal identity management, etc.;
3）Necessary to respond to public health emergencies, or to protect individuals’ lives, health and properties in emergency;
4）Personal data being processed to a reasonable extent for the public interest, such as assisting criminal investigation, national security and national defense;
5）Personal data being disclosed by yourself, or via legitimate public channels such as governmental bodies and media reports; and
6）Other circumstances stipulated by laws and regulations.
IV. How we use personal data
We may use your personal data for achieving product features and services, providing support for products and services, processing your transactions, contacting you, complying with applicable laws and regulations, and other purposes for which you have expressly agreed. Where there is a change in the purpose of personal data processing, we will immediately notify you and, continue to use your personal data only with your new consent.
We may also use your personal data to make automated decisions for specific products, services or webpages. We promise that such automated decision-making is transparent, and the results are fair and equal. The decisions we make through automated decision-making will not have any significant impact on your personal rights, and we will not impose unreasonable differential treatment on you based on the results of such automated decision-making.
We will not send you Laiye Technology’s marketing materials through digital channels (e.g., emails and text messages) without your prior consent. The channels to subscribe and unsubscribe from receiving Laiye Technology’s marketing materials will be provided to you in the product features, service options or “Special Reminders for Privacy Policy.”
V. How we protect and store personal data
We have implemented a dual protection mechanism combining management and technical tools (hereinafter referred to as the “information security measures”) to protect your personal data. In particular, the management measures consist of information security policy, confidentiality policy, employee’s code of conduct, information security incident plans, etc., and we have established an Information Security Management Committee to take in charge of the foregoing management measures. The technical measures include SSL link encryption, VPN private networks with double protection of certificate and password that are isolated from each other according to different purposes, authority control of data center, etc. We have considered the nature, classification, and consequences of leakage for different types of personal data, so to establish information security measures accordingly and respectively for various circumstances.
Our retention of personal data is limited to the purpose of collecting personal data and complying with the relevant requirements of this Policy and applicable laws. Please note that, after achieving the purpose of collecting personal data, we may continue to store your personal data in accordance with laws and regulations, for the purposes such as dispute resolution, audit and inspection, assisting criminal investigation, etc. Unless otherwise specified in relevant Special Reminders for Privacy Policy, we will store your personal data only for the period necessary to achieve relevant purposes of data collections. Once such purposes have been achieved, your personal data will be deleted or be stored in a way that cannot be used to directly or indirectly identify you.
VI. How we share personal data
Your personal data may be shared among affiliated companies represented by Laiye Technology (hereinafter referred to as “Intra-group Share”). With your prior express consent, Intra-group Share is limited to the following circumstances:
1） Intra-group Share may be necessary for providing you with certain products and services, which may be provided jointly by several affiliated companies represented by Laiye Technology. In such cases, we can provide you with such products and services only if your information is shared within the group.
2） When you participate in events (such as forums and lucky draws) co-hosted by several affiliated companies represented by Laiye Technology, your personal data will be shared among the hosting companies.
3） Intra-group Share may be conducted with your authorization to the extent permitted by laws and regulations, and such share will be reasonable and in good faith.
Meanwhile, without your consent, we will not share your personal information with any third parties except under the following circumstances:
1） We may share your personal information with affiliates, third-party service providers and agents of Laiye Technology, for the following purposes:
（a）To the extent necessary, the provision of relevant products and services;
（b）To the extent necessary, our performance of the contracts entered between you and us;
（c）The fulfillment of our obligations and exercise of our rights under this policy;
（d）We may engage third-party professional agencies to process your personal data on behalf of us to improve the efficiency and accuracy of data processing, and to reduce costs. Your personal data will not be transferred to such third-party professional agencies without your prior consent. With your consent, we will require the third-party professional agencies to take information security measures to protect your personal data by means such as written agreements and on-site audits, and when the principal-agent relationship is terminated, require the professional agencies to return or destroy such information per our instructions.
（e）With your prior consent, we may share your personal data with third parties. Please note that the third-party services (e.g., services provided by counterparties of transactions, third-party website operators, third-party shopping platform operators, etc.) you access through us and the third parties that receive your personal data through us may have their own privacy policies. When you view a webpage operated by a third party or use an application developed by a third party, such third party may collect, retain, transfer, use or otherwise process your personal data, and such processing of personal data is neither under our control nor subject to this Policy. We will make reasonable commercial effort to request such third parties to take measures to protect your personal data. However, we cannot guarantee that they will honor such requests. You can contact such third parties to review their privacy policies. If you consider it risky to allow such third parties to process your personal data, we suggest that you cease relevant operations to protect your legitimate rights and interests.
We may, without your consent, share, transfer, or disclose your personal information, in accordance with relevant applicable laws and regulations, under the circumstances listed below:
a）For the purpose of fulfilling statutory obligations, such as orders issued by law enforcement agencies;
b）For the purposes that directly relate to national security and defense；
c）For the purposes that directly relate to public safety, public health, and public interests;
d）For the purposes that directly relate to criminal investigation, prosecution, sentences and enforcement；
e）For the purposes of protecting your or other individual’s life, property, and other legitimate interests;
f）Your information has been publicly disclosed by yourself;
g）Your information has been legitimately disclosed by a third party to the public, such as news, public information disclosed by the government, etc.
Unless otherwise stipulated by law, Laiye Technology will not transfer any personal data collected in Mainland China to other countries or regions, including Hong Kong Special Administrative Region, Macau Special Administrative Region, and Taiwan Province.
If you are a user in Hong Kong Special Administrative Region, Macau Special Administrative Region, Taiwan Province, or a country or region outside of China, we may transfer your personal data across border so that you can use our products and services. We will strictly abide by the laws and regulations of relevant countries or regions on cross-border data transfer. If the laws and regulations of the relevant countries or regions are inconsistent with this Policy, the former shall prevail.
VII. How to exercise your rights
We recognize and respect your privacy right, which will not be treated differently based on where you live.
You may, by reaching out to us via the contact information stated herein, review, correct, supplement, delete or otherwise process your personal data that is collected, stored, used, or otherwise processed by Laiye Technology. Please note, we will only respond to your request after verifying your identity and provided information. This is one of our key information security mechanisms. At the same time, some features of the products and services may be unachievable or restricted due to your request. We will remind you when you make such a request, so as not to affect your normal use of our products and services.
Notwithstanding the foregoing, we may not be able to respond to your request in the following circumstances in accordance with relevant laws, regulations and national standards.
1）Your request is directly related to national security or national defense.
2）Your request is directly related to public safety, public health, or significant public interests.
3）Your request is directly related to criminal investigation, prosecution, trial or enforcement of judgments.
4）The response to your request will have adverse impact on other individuals, companies or legal entities.
5）Your request relates to trade secrets.
VIII. COOKIES
COOKIES is a storage technology used in a browser that can be operated by a server. It usually stores credentials and other user information after a user logs in, so to identify the user and provide services. We may track users’ behavior by placing COOKIES.
If you don’t want us to use COOKIES, please refer to Deactivation and Removal of Cookies for deactivating COOKIES.
IX. Protection of minors
We are well aware of the importance of protecting the personal data of minors, and will protect the personal data of minors in accordance with applicable laws and regulations. Meanwhile, we expect parents and guardians to guide and instruct their minors when using our products and services.
If you are a minor, we highly suggest that you read this Policy together with your parents or guardians, and use our products and services or provide us with your information with their consent. We will only process your personal data with the express consent of your parents or guardians to the extent allowed by such consent and applicable laws. If your parents or guardians do not approve that you use our products or services in accordance with this Policy or provide us with your personal data, please immediately cease the use or disclosure, and promptly inform us so that we can take corresponding measures.
XI. Contact us
We have formed an Information Security Management Committee and designated specific officers to take in charge of our data protection issues, including answering and handling your questions, requests, and complaints. If you have any question, requests or suggestions on our data protection policies, please contact us via privacy@laiye.com.