Meike
Zhike Program Service Agreement and Privacy
Policy
This policy applies solely to Meike Zhike’s Program services. Last updated: April 17, 2023
This policy will help you understand the
following:
I. How We Collect and Use Your User
Information
II. How we use cookies and similar
technologies
3. How we share, transfer, and publicly
disclose your user information
IV. How we protect your user information
5. Your rights
VI. How We Handle Children’s Personal
Information
VII. How Your User Information Is Stored and
Transferred Globally
VIII. How This Policy Is Updated
IX. How to Contact Us
We fully understand the importance of your
user information to you and will do our utmost to ensure its security and
reliability. We are committed to maintaining your trust in us and adhere to the
following principles to protect your user information: the principle of
alignment between rights and responsibilities, the principle of clear purpose,
the principle of informed consent, the principle of data minimization, the
principle of security assurance, the principle of user participation, and the
principle of transparency. At the same time, we promise to implement
appropriate security measures in accordance with established industry standards
to protect your user information.
Please read and understand this Privacy Policy
carefully before using our products (or services).
I. How We Collect and Use Your User
Information
(1) Information We Collect and Use When You
Use Our Products or Services
We will only collect and use your user
information for the business functions described in this policy. The purpose of
collecting user information is to provide you with products or services. You
have the right to choose whether to provide such information; however, in most
cases, if you do not provide it, we may be unable to provide you with the
corresponding services or respond to any issues you encounter:
When you use our services, you consent to our
collection of information you voluntarily provide to us or information
necessary to provide services to you, including: network logs, device
information, location information, and other relevant information.
We will use the user information we collect
for purposes such as identity verification, security protection, anti-fraud
monitoring, archiving and backup, and customer security services.
You grant us ongoing authorization to use the
aforementioned information for the duration of your use of this service. When
you stop using the push notification service, we will cease using and delete
the aforementioned information.
We guarantee that we will de-identify or
anonymize collected user information in accordance with the law. Information
that cannot identify a natural person’s identity either on its own or when
combined with other information does not constitute personal information in the
legal sense. If we combine non-personal information with other information to
identify your personal identity, or if we use it in conjunction with your
personal information, we will treat and protect such information as your
personal information in accordance with this Privacy Policy during the period
of combined use.
To better operate and improve our technology
and services, or due to changes in business strategy, if the collection, use,
or processing of user information required for our products or services exceeds
the scope described above, or if we intend to use collected user information
for purposes not specified in this Privacy Policy, or if we intend to use
information collected for a specific purpose for other purposes, we will notify
you within a reasonable period after obtaining your user information or before
processing it, and obtain your authorization and consent.
(2) Exceptions to the Requirement for
Authorization and Consent
Please understand that, in accordance with
laws, regulations, and relevant national standards, we are not required to
obtain your authorization or consent to collect and use your user information
in the following circumstances:
1. Matters directly related to national
security or national defense security;
2. Matters directly related to public
security, public health, or major public interests;
3. Matters directly related to criminal
investigation, prosecution, trial, and enforcement of judgments;
4. Where it is necessary to protect your or
another individual’s vital legal rights and interests, such as life or
property, but obtaining your consent is impractical;
5. Where the user information collected is
information you have voluntarily disclosed to the public;
6. Your user information collected from
legally disclosed sources, such as legitimate news reports or government
information disclosure channels;
7. Necessary for entering into or performing a
contract at your request;
8. Necessary for maintaining the secure and
stable operation of the software and related services, such as identifying and
addressing faults in the software and related services;
9. Where the personal information controller
is a news organization and such collection is necessary for conducting lawful
news reporting;
10. Necessary for statistical or academic
research conducted by academic research institutions in the public interest,
provided that personal information contained in the results is de-identified
when the results of such research are made publicly available;
11. Other circumstances prescribed by laws and
regulations.
II. How We Use Cookies and Similar
Technologies
(1) Cookies
To ensure the proper functioning of the
website, we store small data files called cookies on your computer or mobile
device. Cookies typically contain an identifier, the site name, and some
numbers and characters. With the help of cookies, the website can store your
visit preferences.
We will not use cookies for any purpose other
than those described in this policy. You may manage or delete cookies according
to your preferences. You can clear all cookies saved on your computer, and most
web browsers have a feature to block cookies. However, if you do so, you will
need to manually adjust your settings each time you visit our website.
(2) Web Beacons and Pixel Tags
In addition to cookies, we also use other
similar technologies on our website, such as web beacons and pixel tags. For
example, emails we send to you may contain clickable URLs linking to content on
our website.
If you click on such a link, we will track
that click to help us understand your product or service preferences and
improve our customer service. Web beacons are typically transparent images
embedded in websites or emails. Through pixel tags in emails, we can determine
whether an email has been opened. If you do not wish to have your activities
tracked in this manner, you may unsubscribe from our mailing list at any time.
(3) Do Not Track
Many web browsers include a "Do Not
Track" feature that sends a "Do Not Track" request to websites.
Currently, major internet standards organizations have not established policies
regarding how websites should respond to such requests. However, if "Do
Not Track" is enabled in your browser, all of our websites will respect
your choice.
III. How We Share, Transfer, and Disclose Your
User Information
(1) Sharing
To better serve you, we may share your
information under the following circumstances:
1. Sharing with explicit consent: We will
share your user information with other parties after obtaining your explicit
consent.
2. We may share your user information
externally in accordance with laws and regulations or in response to mandatory
requests from government authorities.
3. Sharing with Our Service Providers,
Business Partners, and Affiliates: Your user information may be shared with our
service providers, business partners, and affiliates. We will only share
necessary user information, and such sharing is limited to the purposes stated
in this Privacy Policy. If our service providers, business partners, or
affiliates wish to change the purpose of processing your user information, they
will seek your authorization and consent again.
4. Sharing with Authorized Partners: To
achieve the purposes stated in this Policy, certain services may be provided by
our authorized partners.We
may share certain user information with our partners to provide better customer
service and user experience. We will only share your user information for
lawful, legitimate, necessary, specific, and explicit purposes, and will only
share the user information necessary to provide the service. To better operate
and improve our technology and services, you agree that we and our authorized
partners may use the collected information for other services and purposes,
provided that such use complies with relevant laws and regulations.
(2) Transfer
We will not transfer your user information to
any company, organization, or individual, except in the following
circumstances:
1. Transfer with explicit consent: We will
transfer your user information to other parties after obtaining your explicit
consent;
2. In the event of a merger, acquisition, or
bankruptcy liquidation, if the transfer of user information is involved, we
will require the new entity holding your user information to continue to be
bound by this Privacy Policy; otherwise, we will require that entity to obtain
your authorization and consent again.
(3) Public Disclosure
We will only publicly disclose your user
information under the following circumstances:
1. After obtaining your explicit consent;
2. Disclosure required by law: We may publicly
disclose your user information when required by law, legal proceedings,
litigation, or mandatory requests from government authorities.
(4) Exceptions to the Requirement for Prior
Authorization and Consent for Sharing, Transferring, or Publicly Disclosing
Information
Please understand that, in accordance with
laws, regulations, and relevant national standards, we are not required to
obtain your authorization or consent to share, transfer, or publicly disclose
your user information in the following circumstances:
1. Matters directly related to national
security or defense security;
2. Matters directly related to public safety,
public health, or significant public interests;
3. Matters directly related to criminal
investigation, prosecution, trial, and enforcement of judgments;
4. Situations where it is necessary to protect
your or another individual’s vital legal rights and interests, such as life or
property, but obtaining your consent is difficult;
5. Information that you have voluntarily
disclosed to the general public;
6. Information collected from legally
disclosed sources, such as legitimate news reports, government information
disclosure, and other channels.
IV. How We Protect Your User Information
(1) We have implemented industry-standard
security measures to protect the user information you provide, preventing
unauthorized access, disclosure, use, alteration, damage, or loss of data. We
will take all reasonable and feasible measures to protect your user
information. For example, data exchanged between your browser and the “Service”
is protected by SSL encryption;We also provide HTTPS
secure browsing on our website; we use encryption technology to ensure data
confidentiality; we employ trusted security mechanisms to prevent malicious
attacks; we implement access control mechanisms to ensure that only authorized
personnel can access user information; and we conduct security and privacy
protection training sessions to reinforce our employees’ understanding of the
importance of protecting user information.
(2) We
will take all reasonable and feasible measures to ensure that we do not collect
irrelevant user information. We will retain your user information only for as
long as necessary to fulfill the purposes described in this policy, unless a
longer retention period is required or permitted by law.
(3) The internet is not a completely secure
environment, and communication via email, instant messaging, and other methods
with other users is not encrypted. We strongly recommend that you do not send
user information through such channels.
(4) We will periodically update and publish
reports on security risks, user information security impact assessments, and
related matters.
(5) The internet environment is not 100%
secure, and we will do our utmost to ensure the security of any information you
send to us. Even though we have made significant efforts and taken all
reasonable and necessary measures, it is still possible that your user
information may be subject to unauthorized access, theft, tampering, or
destruction, potentially resulting in harm to your legitimate rights and
interests. We ask for your understanding of these inherent risks in information
networks and request that you voluntarily assume such risks.
(6) In the unfortunate event of a user
information security incident, we will promptly notify you in accordance with
legal and regulatory requirements regarding: the basic details of the security
incident and its potential impact; the remedial measures we have taken or will
take; recommendations for you to independently prevent and mitigate risks; and
remedial measures for you.We will promptly notify you
of the relevant details of the incident via email, letter, telephone, push
notifications, or other means. When it is impractical to notify each data
subject individually, we will issue a public announcement using reasonable and
effective methods. At the same time, we will proactively report the handling of
user information security incidents to regulatory authorities as required.
V. Your Rights
In accordance with relevant Chinese laws,
regulations, and standards, as well as common practices in other countries and
regions, we guarantee your right to exercise the following rights regarding
your user information:
(1) Access to Your User Information
You have the right to access your user
information, except in cases where exceptions are provided by laws and
regulations.
If you are unable to access this user
information via the links above, you may contact us at any time using our web
form at 或发送电子邮件至meikesmart@sina.com.
We will respond to your access request within 30 days.
For other user information generated during
your use of our products or services, we will provide it to you as long as it
does not require excessive effort on our part. If you wish to exercise your
right of access to data, please contact us at 请发送电子邮件至meikesmart@sina.com.
(2) Correcting Your User Information
If you discover that the user information we
process about you is incorrect, you have the right to request that we correct
it. You may submit a correction request using the methods listed in “(I)
Accessing Your User Information.” If you are unable to correct this user
information via the links above, you may contact us at any time using our web
form at 或发送电子邮件至meikesmart@sina.com.
We will respond to your correction request within 30 days.
(3) Deleting Your User Information
You may request that we delete your user
information in the following circumstances:
1. If our processing of user information
violates laws and regulations;
2. If we collect or use your user information
without obtaining your consent;
3. If our processing of user information
violates our agreement with you;
4. If you no longer use our products or
services, or if you have closed your account;
5. If we no longer provide products or
services to you.
We will evaluate your deletion request, and if
it meets the relevant requirements, we will take appropriate steps to process
it. When you submit a deletion request to us, we may ask you to verify your
identity to ensure account security . After you delete
information from our services, due to applicable laws and security
technologies, we may not immediately delete the corresponding information from
our backup systems; we will securely store your information until the backups
can be purged or anonymized.
(4) Changing the Scope of Your Consent
Each business function requires certain basic
user information to be performed (see “Part I” of
this Policy). You may grant or withdraw your authorization and consent
regarding the collection and use of user information at any time.
Once you withdraw your consent, we will no
longer process the corresponding user information. Please also note that
withdrawing your consent may result in certain consequences, such as our
inability to continue providing you with certain services or specific features;
however, your decision to withdraw consent will not affect the processing of
user information that occurred prior to your withdrawal based on your
authorization.
(5) Account Cancellation by the User
You may close your previously registered
account at any time.
After account cancellation, we will cease
providing products or services to you and, upon your request, delete or
anonymize your information, unless otherwise required by laws and regulations.
This may also result in you losing access to the data in your account; please
proceed with caution.
(6) Obtaining a Copy of User Information
You have the right to obtain a copy of your
user information.
Where technically feasible, such as when data
interfaces are compatible, we may also, upon your request, directly transmit a
copy of your user information to a third party designated by you.
(7) Restrictions on Automated Decision-Making
by Information Systems
In certain business functions, we may make
decisions solely based on non-human automated decision-making mechanisms,
including information systems and algorithms. If these decisions significantly
affect your legitimate rights and interests, you have the right to request an
explanation from us, and we will provide appropriate remedies.
(8) Responding to Your Requests
To ensure security, you may be required to
submit a written request or verify your identity in another manner. We may
first ask you to verify your identity before processing your request.
We will respond within thirty days.
In principle, we do not charge fees for
reasonable requests; however, for repeated requests that exceed reasonable
limits, we may charge a fee to cover costs on a case-by-case basis.We may refuse requests that are groundless and
repetitive, require excessive technical means (e.g., developing new systems or
fundamentally altering existing practices), pose a risk to the legitimate
rights and interests of others, or are highly impractical. Please also
understand that, due to security considerations, requirements of relevant laws
and regulations, or technical limitations, we may be unable to respond to
certain requests, such as in the following circumstances:
1. Requests related to the fulfillment of
legal obligations by the controller of user information;
2. Matters directly related to national
security or defense security;
3. Matters directly related to public safety,
public health, or significant public interests;
4. Directly related to criminal
investigations, prosecutions, trials, and the enforcement of judgments;
5. Where the data controller has sufficient
evidence to indicate that the data subject has acted with malicious intent or
abused their rights;
6. Where it is necessary to protect the vital
legitimate rights and interests (such as life and property) of the data subject
or other individuals, but obtaining the data subject’s
consent is difficult;
7. Where complying with the data subject’s
request would result in serious harm to the legitimate rights and interests of
the data subject or other individuals or organizations;
8. Where trade secrets are involved.
VI. How We Handle Children’s
Personal Information
We take the protection of children’s
personal information very seriously. Our products, websites, and services are
primarily intended for adults. Children should not create their own user
accounts without the consent of a parent or guardian. Although the definition
of a child varies by local laws and customs, we consider anyone under the age
of 14 to be a child.
In cases where we collect children’s user
information with the consent of a parent or guardian, we will only store, use,
or publicly disclose such information when permitted by law, with the explicit
consent of the parent or guardian, or when necessary to protect the child.
Otherwise, we will endeavor to delete the relevant data as soon as possible.
Given the limitations of current technology
and business models, it is difficult for us to proactively identify children’s
personal information. If you discover that we have collected a child’s
personal information without our knowledge or without obtaining verifiable
parental or guardian consent in advance, please contact us promptly. We will
make every effort to delete such information as soon as we become aware of it.
If we discover such a situation on our own, we will also delete the information
promptly, except where required by law to retain it.
VII. How Your User Information Is Stored and
Transferred Globally
In principle, user information collected and
generated within the People’s
Republic of China will be stored within the People’s
Republic of China. We will retain your user information only for the period
necessary to fulfill the purposes and uses described in this Policy and for the
minimum period required by laws and regulations. After the aforementioned
retention period expires, we will delete your user information or anonymize it
in accordance with applicable laws and regulations. We may need to retain relevant
data for a longer period if otherwise required by laws and regulations, or for
purposes such as public interest, scientific or historical research, or if you
have provided separate authorization or consent.
Since we provide products or services through
resources and servers located worldwide, this means that, with your
authorization and consent, your user information may be transferred to
jurisdictions outside the country or region where you use our products or
services, or may be accessed from such jurisdictions.
Such jurisdictions may have different data
protection laws, or may not have relevant laws in place at all. In such cases,
we will ensure that your user information receives protection equivalent to
that provided within the People’s
Republic of China. For example, we may request your consent for the
cross-border transfer of user information, or implement security measures such
as data de-identification prior to cross-border data transfers.
VIII. How This Policy Is Updated
Our Privacy Policy may change. We will not
reduce the rights you are entitled to under this Privacy Policy without your
explicit consent. We will post any changes to this Policy on this page.
For material changes, we will also provide
more prominent notice. Material changes referred to in this Policy include, but
are not limited to:
1. Significant changes to our service model,
such as the purpose of processing user information, the types of user
information processed, or the manner in which user information is used;
2. Significant changes in our ownership
structure or organizational structure, such as changes in ownership resulting
from business restructuring, bankruptcy, or mergers and acquisitions;
3. Changes in the primary recipients of user
information sharing, transfer, or public disclosure;
4. Significant changes to your rights
regarding the processing of user information and the methods for exercising
those rights;
5. Changes to the department responsible for
user information security, contact information, or complaint channels;
6. When a user information security impact
assessment report indicates a high risk.
We will also archive previous versions of this
policy for your reference.
IX. How to Contact Us
If you have any questions, comments, or
suggestions regarding this Privacy Policy, please contact us via the following
methods:
Email: meikesmart@sina.com
Generally, we will respond within thirty days.