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    PRIVACY POLICY

    Privacy policy

    Whale Cloud Technology Co., Ltd. and its affiliates (collectively, “Whale Cloud Technology” or “Company”) respect your privacy and emphasize the security of personal data. When using our products and/or services, we may collect and use your personal data with your consent and legitimate basis that applies to our contract relationship or legitimate interests.

    Whale Cloud Technology Privacy Policy (“this Policy”) describes how we collect, use, save, share and transfer your personal data, and inform you about how to manage your personal data. Please read carefully and have a thorough understanding of this Policy before you submit your personal data to our Company, and visit our website regularly to have a better knowledge of the update on this Policy.

    This Policy applies to Whale Cloud Technology websites, products, and services that display or provide links to this Policy. But please note, other more specific Privacy Policies may apply to special websites.

    If you have issues about this Policy, please inform us by sending emails to rc.complianceaudit@iwhalecloud.com.

    This Policy describes:

    • The Personal Data We Collected
    • How We Use the Personal Data Collected
    • How We Share, Transfer & Disclose Your Personal Data
    • How We Store Your Personal Data
    • How We Protect Your Personal Data
    • How You Protect Your Personal Data
    • How We Use Cookies & Similar Technologies
    • How We Protect Children’s Personal Data
    • Updates to This Policy
    • How to Contact Us
    1. The Personal Data We Collected

    Personal data means any data that, related to an identified or identifiable natural person. An identifiable natural person refers to especially, for example, who can be identified directly or indirectly by name, ID number, location data, network identification symbol, and economic, cultural, social identity, etc.

    The personal data collected is divided into the following types:

    1) Account Information
    You need to provide mobile number or email for authentication when registering service accounts relate to Whale Cloud Technology, or provide additional information such as avatar, nickname, birthday, etc. We will achieve your verification information from third party server under your authorization when you login Whale Cloud Technology business platform by third party (such as Facebook, Twitter, WeChat) account, which you can also refuse the access to our products or services. The server will keep the access token granted by the third-party platform and share among specific services used by users to avoid repeated login in third party server.

    2) Location Information
    We may collect and process data about the actual location of the related user/terminal device with your consent when you use Whale Cloud Technology Terminal APP with location function, such as family positioning and mobile retrieval, but we will not achieve your tracks by continually collecting your location data.

    3) After Sales Information
    We will collect necessary information to ensure favorable after sales service, such as your name, phone number, device information and default description, when you need an after sales service or feedback problems encountered in use. You can offer us information based on the specific service required, for example, you need to offer us your mail address and receipt information when you need the after sales mail service.

    4) Access Service Information
    We will record behavior information when you access to relevant services of Whale Cloud Technology by product’s information collection function, including access time, search query terms, network identity information, IP address, etc., what’s more, where permitted by law, we will achieve your personal data from legitimate public and commercial sources for precise and personalized service.

    5) Other Information

    Users can deny to offer information in some services, such as cloud backup, cloud disk provided by Whale Cloud Technology APP, which will save the user’s address book, SMS, photo, etc. to the server, but they may fail to or use partial functions of related services only. We will required your resume when you applying for a job on our website.

    Sensitive personal data is a kind of special personal data which is generally defined as any data related to the following respects: race or ethnic origin, political opinions, religious beliefs, philosophical beliefs, union membership, personal genetic data, biometric data, health data, sexual life, sexual orientation, etc. In some cases, personal sensitive data may also include unique identifiers like criminal allegations or judgments, precise geographic location information, financial and bank account numbers, and government-issued social security numbers, driver’s licenses, and passport numbers.

    We need to collect or process your personal data in case that you purchase products or order services from us, then we will need to collect payment sensitive personal data such as bank card number. In such case, we will process it in accordance with applicable legal requirements, such as asking for your consent in advance.

    1. How We Use the Personal Data Collected

    We will collect your personal data directly or indirectly when you using our product, service or website, or there is an information interaction between us. We will collect your personal data directly in circumstances that you call our hotline, create a website account or participate in our brand events, etc. While, the website will indirectly collect your personal data through technologies, such as cookies.

    Whale Cloud Technology will process some personal data related to you or your relevant personnel in the foundation of our relationship and the products and services we provided or would like to provide. We will only collect necessary data package to realize product function in line with the principles of lawfulness, justification and necessity.

    We may use your personal data for the following purposes:

    -Fulfilling an order;

    -Creating & managing your account;

    -Registering services for you/your device;

    -Providing the service or functions you requested;

    -Providing you with a subscription to our information;

    -Providing after-sales service for your devices;

    -Providing online customer service consultation, suggestions & complaints;

    -Sending you important notices related to security or service upgrade;

    -Analyzing access to service data to improve our products and services;

    -Providing a good experience for your use of the website/product;

    -Troubleshooting when you send us error reports;

    -Improving our loss prevention and anti-fraud programs;

    -Complying with and enforcing applicable legal requirements;

    -Other uses for your consent.

    When we want to use your personal data for other purposes not covered by this Policy, or to use the data for purposes other than your prior consent, our products or services will ask for your consent in advance, such as through a pop-up window. , blackened fonts, etc. to display the updated content, it’s upon to you whether you agree to the update. You may revoke this consent at any time in accordance with the law, but this may limit your rights to use the product or service.

    Please fully understand that, in accordance with applicable law, we collect and use personal data in the following situations without your authorization:
    1. Related to national security and national defense security;
    2. Related to public security, public health, and major public interests;
    3. Related to legal procedures such as criminal investigation, prosecution, trial and execution of judgments;
    4. Related to the maintenance of the personal interests of the individual or other individuals (such as life);
    5. Required for legal news reporting;
    6. Other circumstances as stipulated by laws and regulations.

    1. How We Share, Transfer & Disclose Your Personal Data

    To ensure the security of your personal data, we share, transfer or disclose your personal data in accordance with the minimum legal requirements and in compliance with applicable legal requirements:
    a. As a global company, we may share your personal data between Whale Cloud Technology and its affiliate in order to provide you with timely service when there is a business requirement;
    b. Share the minimum and necessary information with our authorized business partners to serve you better;
    c. When it comes to mergers, acquisitions, bankruptcy liquidation, asset transfer or similar transactions, we will require new companies and organizations that hold your personal data to continue to be subject to the requirements and commitments of this Privacy Policy, and restrictions on security measures, if it involves personal data transference. For example, do not exceed the purpose of using the above personal data, otherwise we will ask the company or organization to re-authorize your consent.

    1. We may also provide information to law enforcement agencies/government agencies if we believe that the disclosure complies with any applicable law or responds to legal proceedings;

    For companies, organizations and individuals with which we share personal data, we will sign a rigorous data processing agreement with them to process personal data in accordance with our security standards, the requirements of this policy and related confidentiality and security measures. If the country in which we share, transfer or disclose personal data does not have the applicable laws that protect personal data to the same extent as in your country, such as from the European Economic Area to countries that do not have appropriate personal data protection laws, we will follow Article 7 in this Policy to ensure the legality of data transfer and the security of your personal data.

    1. How We Store Your Personal Data

    In general, we retain your personal data for the shortest period of time necessary to achieve its purpose. However, in the following cases, we may change the storage time of personal data due to legal requirements:

    -In order to comply with applicable laws and regulations and other relevant regulations;

    -In order to comply with court decisions, rulings or other legal procedures;

    -In order to comply with the requirements of relevant government agencies or statutory authorized organizations;

    -We have reason to believe that we need to comply with relevant laws and regulations;

    -For the purpose of implementing the relevant service agreement or this Policy, safeguarding the public interest, and protect personal property safety or other legal rights of our customers, us or our affiliates, other users or employees.

    When our products or services cease to operate, we will notify you by, for example, push notifications, bulletins, etc., and delete or anonymize your personal data within a reasonable period of time.

    Your personal data is generally stored in the location where the business is conducted, but may also be stored outside of your country, which is related to the location of our data center, and we will take steps to ensure that we apply this Privacy Policy and the location of the data stored apply to legal requirements to deal with the data we collected. To the extent permitted or required by law, we will inform you of the loss, misuse or alteration of personal data that may pose a significant risk to you, so that you can take appropriate measures to effectively protect your rights.

    1. How We Protect Your Personal Data

    Whale Cloud Technology will strive to protect personal data from unauthorized access, disclosure, modification, damage or loss and other forms of illegal processing by strengthening the physical, management and technical security measures of personal data, such as access control systems, surveillance systems, encryption, anonymity or pseudonymization, employee training, etc., We have a dedicated business continuity plan to ensure that we can provide services to our customers continuously; our information security policies and procedures are designed in strict accordance with international standards, and are regularly reviewed and updated, what’s more, our security measures are tested by third parties to meet our business needs, technology changes and regulatory requirements. Whale Cloud Technology has passed ISO 27001 information security certification to ensure the security of your personal data.

    1. How You Protect Your Personal Data

    You may access, update and delete the registration data and other personal data you provide while using our services, or you may follow the notice guidelines to contact us. The scope and manner in which you access, update, and delete personal data will depend on the specific service you use.

    We will collect and use your data solely as described in this Policy for the functionality of our products or services.

    We may ask you to authenticate to keep your account secure, when you need to access, update, or delete information.

    Please understand that we may not be able to meet all of your requirements due to technical limitations, legal or regulatory requirements. If you have any questions about accessing and managing your personal data, you can contact us in accordance with Article 10 of this Policy. We will respond to your request within 30 days.

    1. How We Use Cookies & Similar Technologies

    Our website uses cookies and other similar technologies to distinguish you from other users of our website. This will improve user experience and our website.

    Cookie is generally divided into two types: session cookies and persistent cookies. Session cookies can help you navigate the site efficiently and track the progress of your browsing pages so that you don’t need to provide repeated data during the current visit. Session cookies are stored in the temporary memory and will be deleted when the web browser is closed. Persistent cookies store user browser preferences, which are stored on your device and remain in effect when you restart your browser. For example, persistent cookies is allowed to remember your settings such as language, font size on your computer or mobile device, which means that a user does not need to reset for every visit.

    You can clear all the cookies saved on your computer or directly delete the cookies stored on the device, but by doing so, you have to change the user settings every time you visit our website. Most web browsers provide the option of blocking cookies, if you want to manage cookies through web browser, you can refer to the introduction from browser developer or search on the Internet. For details, please visit AboutCookies.org or http://www.iwhalecloud.com/cookie-policy.

    1. How We Protect Children’s Personal Data

    We values the protection to children’s personal data. In accordance with the relevant laws and regulations, if you are a child under the age of 18, you should obtain the consent of your parent or legal guardian before using our services or products.

    If you are a guardian of a child, please contact us through Article 10 when you have doubts about the personal data of the child you are monitoring.

    1. Updates to This Policy

    We may update the Policy at any time. If there is an update on this Policy, we will release the updated Privacy Policy on any changes. You can visit the website regularly to have a better understanding of the update.

    If the update results in the loss of your right under this Policy, we will notify you through channels like sending emails to you, or prompt under the prominent position of the page before the updates become effective.

    Last Updated: August 15, 2019

    1. How to Contact Us

    If you have any issues on this Policy or others, please contact us through rc.complianceaudit@iwhalecloud.com.

    You can also fill in relevant information and send your issues to li.quanjiang@iwhalecloud.com.

    Or mail to the following address: No. 888, Zhengfang Middle Road, Nanjing, Jiangsu, China. Whale Cloud Technology Co., Ltd. Compliance Committee

    Postal Code: 211153