Introduction
Beijing Yicai Hongye Management Consulting Co., Ltd (hereinafter referred to as “CTG” or “the Company”) attaches great importance to the protection of users' privacy and personal information. When you use CTG services through computer, mobile terminals or other devices, CTG may collect and use information about you. Through this Policy, CTG would like to explain to you what information may be collected about you when you use our services and how such information is collected, used, stored and shared, as well as the ways in which you can access, control and protect such information.
This Privacy Policy is an agreement between you, as a user, and CTG regarding the use of the Platform, and the use of CTG related services. Unless the user has read and accepted all the terms of this agreement, the user is not authorized to download or use the services related to the Platform. The user is deemed to have read and agreed to the above constraints by downloading, using, logging in and other behaviors.
This Policy was last updated on January 01, 2022.
Contents
This Policy will help you understand the following:
I. How we collect and use your personal information
II. How we share, transfer and publicly disclose your personal information
III. How we use Cookies and similar technologies
IV. Applicable exceptions
V. Protection of minors' personal information
VI. How this Policy will be updated
VII. How to contact CTG
CTG recognizes the importance of your personal information and makes every effort to keep your personal information safe and secure. CTG is committed to maintaining your trust in our company and adhering to the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of clarity of purpose, the principle of opt-in consent, the principle of minimum necessity, the principle of ensuring security, the principle of subject participation, and the principle of openness and transparency. At the same time, CTG is committed to protecting your personal information by adopting appropriate security measures in accordance with the industry-proven security standards.
I. How we collect and use your personal information
In order to provide you with services, optimize CTG services, and protect information security, CTG collects and uses your personal information in the following ways:
(i) Collection of user information
1. CTG provides you with the right to use the information on the Platform through the Internet and allows you to read the contents, register for activities and download reports on the Platform. When using this platform for service inquiries, you are required to provide some necessary information, such as: real name, address, business name, industry, size, position, department, telephone number and e-mail address.
2. We may also collect and store the following data: your identifier in the Platform, latitude and longitude, gender, age, user-triggered events, errors, and page views, in addition to information such as your end-user's IP address, device type, region, and so on.
(ii) Use of user information
1. The Company will use the information collected through your behavior on this website to provide you with more in-depth support and services.
2. You agree that the Company may disclose or use your personal information to improve the Company's services and to enable the Company's services to meet your requirements, so that you can get a good experience when using the Company's services.
(iii) Other uses
The Company will ask for your prior consent to use the information for purposes other than those stated in this policy, or to use the information collected for a specific purpose for other purposes. The Company collects and uses the above information for the purpose of providing better services and will notify you by means including, but not limited to, WeChat notification, email, phone call or SMS.
II. How we share, transfer and publicly disclose your personal information
(i) Sharing
We will not share your personal information with any companies, organizations and individuals other than the technical service providers of this product, except in the following cases:
1. Sharing with explicit consent: After obtaining your explicit consent, the Company will share your personal information with other parties.
2. The Company may share your personal information externally in accordance with the laws and regulations, or the mandatory requirements of governmental authorities.
3. Except for the following circumstances, we and our affiliates will not share your personal information with any third party without your consent.
We, as well as our affiliates, may share your personal information with our affiliates, partners and third-party service providers, contractors and agents (e.g., communication service providers who send emails or push notifications on behalf of the Company, mapping service providers that provide location data to the Company), who may not be located in your jurisdiction, for the following purposes:
(1) To provide you with CTG services.
(2) To fulfill the purposes described in the section “How we may use the information”.
(3) To fulfill our obligations or exercise our rights under the User Service Agreement or this Privacy Policy.
(4) To understand, maintain and improve CTG services.
4. We or our affiliates may also retain, store or disclose your personal information for the following purposes:
(1) To comply with applicable laws and regulations.
(2) To comply with the provisions of a court order or other legal process.
(3) To comply with the requirements of the relevant governmental authorities.
(4) For purposes reasonably necessary to comply with applicable laws and regulations, to safeguard the public interest, or to protect the personal and property safety or legitimate rights and interests of the Company's customers, group companies or their subsidiaries, other users or employees.
5. If CTG or our affiliates share your personal information with any of the above mentioned third parties, CTG will endeavor to ensure that such third parties comply with this Privacy Policy and other appropriate confidentiality and security measures that CTG requires them to comply with when using your personal information.
(ii) Transferring
The Company will not transfer your personal information to any companies, organizations or individuals, except in the following cases:
1. With your prior express consent or authorization;
2. Where required by applicable laws and regulations, legal proceedings, mandatory administrative or judicial requirements;
3. In line with the relevant agreements signed with you (including the electronic agreement signed online and the corresponding platform rules) or other legal documents.
(iii) Publicly disclosure
We will only publicly disclose your personal information under the following circumstances and with industry-standard security measures in place:
1. To disclose the personal information you have specified in accordance with your needs and in the manner of disclosure to which you have expressly consented;
2. In the event that your personal information must be provided in accordance with the requirements of laws and regulations, mandatory administrative enforcement or judicial requirements, the Company may publicly disclose your personal information in the manner and type of personal information requested. Subject to compliance with laws and regulations, when CTG receives a request for such disclosure, CTG will request that the appropriate legal documents, such as subpoenas or letters of inquiry, must be produced. CTG strongly believes that information requested from us should be as transparent as possible to the extent permitted by law. CTG carefully scrutinizes all requests to ensure that there is a legitimate basis for the request and that the information requested for disclosure is limited to data that law enforcement has a legitimate right to obtain for specific investigative purposes. Documents disclosed by CTG are protected by encryption keys as permitted by laws and regulations.
(iv) Realization of shared information related to advertising
1. Advertising push: The Company may use your information to provide or promote our or third parties' goods and services by sending you marketing information through the Company's services, email or other means. Or, we may share indirect image tags and de-identified device information or anonymized information that does not identify you personally with partners who entrust us with their promotions and advertisements, in order to help them increase the effective reach of their advertisements without identifying you personally.
2. Advertising statistics: We may share and analyze de-identified device information or statistical information with service providers, vendors and other partners of the business. Such information is difficult or impossible to correlate with your true identity, but will help the Company analyze and measure the effectiveness of advertising and related services.
(v) Types of personal information that may be shared externally
The types of personal information that may be involved in public disclosure: reading records, length of use, browsing records, feedback records, favorites records.
The Company is aware of the corresponding legal responsibility for sharing, transferring, or publicly disclosing personal information externally, and will take reasonable measures to safeguard the security of personal information.
(vi) Exceptions to prior authorized consent for sharing, transferring, or publicly disclosing personal information
In the following cases, sharing, transferring, or publicly disclosing personal information does not require your prior authorized consent:
1. Those related to national security and national defense security;
2. Those related to public safety, public health, and significant public interest;
3. Those related to the investigation, prosecution, trial and enforcement of sentences for crimes;
4. For the purpose of safeguarding the life, property and other important legal rights and interests of you or other individuals, but it is difficult to obtain the consent of you or other individuals;
5. Personal information that you disclose to the public on your own;
6. Personal information collected from lawful public disclosure of information, such as lawful news reports, government information disclosure and other channels.
In accordance with the law, the sharing or transferring of personal information that has been de-identified, and which ensures that the recipient of the data is unable to recover and re-identify the subject of the personal information, is not considered to be an act of sharing, transferring or publicly disclosing the personal information externally, and such data will be stored and processed without separate notification to you and without your consent.
If we cease to operate a product or service, we will promptly cease to continue to collect your personal information, notify you of the cessation of operation in the form of an individual notice or announcement, and delete or anonymize personal information in our possession.
III. How we use Cookies and similar technologies
(i) Cookies
1. To ensure proper functioning, the Company stores small data files called Cookies on your computer or mobile device, which usually contain an identifier, the name of the site, and some numbers and characters. Cookies enable us to provide you with a more attentive and personalized service and allow you to set your specific service options.
2. We will not use cookies for any purpose other than those described in this Policy. You can manage or delete cookies according to your own preferences; you can clear all cookies saved on your computer or cell phone, and most web browsers are equipped with a function to block or disable cookies, which you can configure in your browser; blocking or disabling cookies may affect your use of, or prevent you from fully utilizing, all of the products and/or services provided by CTG.
(ii) Web beacons and pixel tags
In addition to cookies, CTG may use other similar technologies such as web beacons and pixel tags on its website in the future based on program updates. For example, an email or text message that CTG sends to you may contain a click-through URL that links to content on our website, and if you click on the link, CTG tracks the click to help CTG understand your product or service preferences and improve customer service. Web beacons are typically a transparent image embedded on a website or in an email. With the help of pixel tags in emails, CTG is able to know if an email has been opened. If you do not want your activity to be tracked in this way, you can unsubscribe from our mailing list at any time.
IV. Applicable exceptions
(i) You consent to the processing of your personal information for the purposes and in the manner described in this Privacy Policy. The Services may include or link to social media or other services (including websites) provided by third parties. For example:
1. You use the “Share” button to share certain content to our Services, or you use a third-party connectivity service to log into our Services. These functions may collect information about you (including your log information) and may install cookies on your computer in order to function properly;
2. We provide links to you through advertisements or other means of our services so that you can access the services or websites of third parties.
Such third parties' social media or other services may be operated by related third parties or by CTG. As long as you do not delete the shared information, the information will remain in the public domain; even if you delete the shared information, the information may be independently cached, copied, or stored by other users or unaffiliated third parties not under our control, or kept in the public domain by other users or such third parties. The Company shall not be responsible for any disclosure of your information if you disclose or share the information through such channels. Therefore, the Company reminds and asks you to carefully consider whether to disclose or share your information through the above channels.
Your use of such third parties' social media or other services (including any personal information you provide to such third parties) is subject to the terms of service and privacy policies of such third parties, which you need to read carefully. This Privacy Policy applies only to information collected by us and does not apply to services provided by any third party or to any third party's rules for use of information, and we are not responsible for any third party's use of information provided by you.
(ii) Certain personal information may be regarded as sensitive personal information due to its specificity, such as your race, religion, personal health and medical information, etc., as well as identification documents, personal biometric information, property information, whereabouts, and information on minors. Sensitive personal information is more strictly protected than other personal information. Please be aware that the content and information (e.g., photos of your social activities) you provide, upload or post when using our services may reveal your sensitive personal information. You need to carefully consider whether to disclose sensitive personal information when using our services. You agree that your sensitive personal information is processed for the purposes and in the manner described in this Privacy Policy.
V. Protection of minors' personal information
The Company attaches importance to the protection of minors' information. If you enter the information of minors when using the Business Processing Service, you are advised to ask the legal guardian of such minors to read this Privacy Policy carefully and to use the Company's services or provide information to the Company with the consent of the guardian. In cases where personal information of minors is collected through the use of our products or services with the consent of the guardian, the Company will only use, share, transfer or disclose this information as permitted by law or regulation, with the express consent of the guardian, or as necessary for the protection of minors. By consenting to the processing of your personal information and the information of minors for the purposes and in the manner described in this Privacy Policy, the Company recognizes and assumes that you are the legal guardian of such minors and that you have carefully read the terms of this Privacy Policy. The Company will protect the personal information of minors in accordance with relevant national laws and regulations and the provisions of this Privacy Policy.
VI. How this Policy will be updated
In order to provide you with better service, this Privacy Policy will be updated accordingly. For significant changes, the Company will also provide more prominent notification (the Company will explain the specific changes to the Privacy Policy by means including, but not limited to, SMS push notifications or special alerts on web pages).
Significant changes referred to in this Policy include, but are not limited to:
1. Significant changes in the Company's service model. Such as the purpose of processing personal information, the type of personal information processed, and how personal information is used.
2. Changes in the primary recipients of personal information to be shared, transferred or publicly disclosed.
VII. How to contact CTG
If you have any questions, comments or suggestions about this Privacy Policy, please call: 400-666-8686
Thank you again for your trust and use of CTG services!