Privacy Policy

Update Date: August 11, 2022

This privacy policy is an integral part of the CUUNION editing service agreement. When you agree to the CUUNION editing service agreement, you are deemed to have agreed to the entire content of this privacy policy. CUUNION will update this Privacy Policy from time to time.

We attach great importance to your privacy, and protecting user privacy is the key principle of CUUNION. Before you use the services provided by CUUNION, please read and thoroughly understand this policy. Before using our products or services, please Read and understand this “Privacy Policy” carefully, and use related products or services after confirming your full understanding and agreement. Please let us know if you have any questions. If you continue to use CUUNION’s editing products or application services, it is deemed that you accept the relevant terms of this “Privacy Policy”.

CUUNION has the right to update the “Privacy Policy” from time to time according to business changes and user feedback. Once the content of this “Privacy Policy” is changed, CUUNION will use CUUNION to change the content after the change is confirmed. It will be announced to users on the terminal or through the update of relevant webpages of CUUNION, and it will be notified to you through prominent notices.

We promise you:

This Privacy Policy sets out how the CUUNION platform and its affiliates (CUUNION CO., LTD., hereinafter referred to as “CUUNION” or “we”) collect, use, disclose, process and protect your use of our Information provided to us when using products and services; if we ask you to provide certain information in order to verify your identity when using CUUNION’s products and services, we will strictly abide by this Privacy Policy and/or our User Terms and Conditions to use this information.

In this Privacy Policy, “personal information” refers to the information itself or data that can identify a specific individual after being linked to other information about an individual that CUUNION has access to. By using CUUNION’s products and services, you represent that you have read, acknowledged and accepted all the terms described in this Privacy Policy, including any changes we may make at any time. We are committed to protecting the privacy, confidentiality and security of your personal information in compliance with applicable laws, including your local data protection regulations.

In the end, all we want is to bring the best experience to our users. If you have any questions about the data processing practices outlined in this Privacy Policy, please contact our Data Protection Officer at info@cuunion.co so that we can address your specific needs. We are happy to address your question directly.

A. What information is collected and how is it used?

1. Types of information collected

In order to provide you with our services, we will ask you to provide personal information necessary to provide you with the services. If you do not provide personal information, we may not be able to provide you with our products or services.

We will only collect information that is necessary for the services you have selected, specific, explicit and legitimate purposes, and will not further process the information in a manner inconsistent with those purposes. Depending on the services you choose, we may collect one or more of the following information (whether or not it is personal information):

(1) Information you provide to us or upload (including your contact information): We will collect some of the personal information necessary for the corresponding service according to the service you choose. For example, if you submit an order on CUUNION, you may provide your name, contact information, email address, shipping address, order information, invoice information, etc.

(2) Information related to you designated by us: We may use the CUUNION account and the above information you provide to verify your identity to ensure that we are providing services for you.

(3) Order record information: If you use CUUNION to purchase goods, we may collect information about the goods or services you use to purchase them. For example, commodity purchase records, after-sales service records, payment records, customer service voice call records, online session records, user evaluation records, etc.

(4) Device or SIM card related information: Information related to your device. For example, IMEI number, operator information, software version information.

(5) Application information: mobile phone IP, DNS, gateway, CDN and application information required for download speed measurement.

Other information: When you use some functions, we will collect some of your information after obtaining your consent. For example, when you evaluate products or communicate with customer service, we will collect your photo album picture information. Unless it must be collected in accordance with relevant laws and regulations, refusing to provide this information will only prevent you from using relevant specific functions, but will not affect your normal use of other functions of CUUNION.

We may also collect other types of information that are not directly or indirectly associated with an individual and are clustered, anonymized or de-identified. For example, we will automatically collect your log information about page opening, closing, click behavior, first visit date, etc. The purpose of collecting such information is to improve the services we provide to you. The type and amount of information collected depends on how you use, join or engage with our products and/or services.

2. How this personal information will be used

(1) The purpose of collecting personal information is to provide you with products and/or services and to ensure that we comply with applicable laws. You hereby consent to our processing and disclosure of personal information to our affiliates, third-party service providers (defined below) for the purposes set forth in this Privacy Policy.

(2) We may use your personal information for the following purposes:

* To provide, process, maintain, improve, develop our products and/or provide services to you, including after-sales service and customer support, and services provided through the device or website.

* To communicate with you about your equipment, service or enquiry requests (e.g. updates, customer inquiries support, information about our events, notifications), etc.

* To conduct related promotional activities, such as providing promotional and promotional materials and updates. For more information on promotions and promotions, see the Direct Promotions section below.

* To analyze and develop statistical information related to the use of our products or services to better improve our products or services.

* Store and maintain information about you for the purposes of running our business or complying with legal obligations.

3. Further details on how we use your information (which may include personal information) are provided below:

(1) Process your order. Information related to e-commerce orders may be used to process the order and related after-sales services, including customer support and re-shipping. Additionally, the order number will be used to cross-check the delivery partner’s order with the actual delivery of the package. Recipient information, including name, address, phone number and zip code will be used for delivery. The list of purchased items is used to print the invoice and enables the customer to identify the items in the package.

(2) Show and recommend goods or services for you. In order to improve our products or services and provide you with personalized information search and transaction services, we will extract features such as your browsing and search preferences based on your browsing and search records, device information, and order information, and conduct searches based on feature tags. Indirect crowd portraits and display and push information.

(3) Risk prevention. In order to improve the security of your use of our services, protect the security of users’ personal information, and prevent malicious fraud, we will verify your IMEI number and operator information. If you do not agree to provide the aforementioned information, risk control verification may not be completed.

(4) Send notification. We may use your personal information to send important notices, such as notices about orders and changes to our terms, conditions and policies.

4. Direct promotion

We may use your name, phone number, address, CUUNION account, IMEI number to provide you with promotional materials related to products and services. In order to provide a better user experience, we will recommend the above products, services and activities based on your device information, CUUNION account information, browsing and search records, order information, etc. You have the right to terminate our use of personal data planned for direct marketing. If you no longer wish to receive certain categories of emails, you may unsubscribe via the unsubscribe link at the bottom of each email. We will not pass your personal information to our business partners for direct marketing.

B. How we use cookies and similar technologies

To ensure the proper functioning of the website, we store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of cookies, websites can store data such as your preferences or the items in your shopping cart.

We will not use cookies for any purpose other than those described in this policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer, most web browsers have a function to block cookies. However, if you do this, you will need to personally change your user settings each time you visit our website.

Please understand that some of our services can only be achieved through the use of cookies. If your browser or browser additional services allow it, you can modify the acceptance level of cookies or reject CUUNION’s cookies, but rejecting CUUNION’s cookies may affect your safe access to CUUNION’s policies in some cases. Website and use of services provided by CUUNION.

C. How do we share, transfer and publicly disclose your personal information

1. Data sharing

We will not share your personal information with companies, organizations and individuals other than CUUNION, except in the following cases:

(1) Sharing with prior authorization: Obtain your express consent or authorization in advance.

(2) Sharing under legal circumstances: Share your personal information externally when necessary in accordance with applicable laws and regulations, legal process requirements, and mandatory administrative or judicial requirements.

(3) Sharing with third parties such as partners: When you purchase goods or services in CUUNION, in order to ensure the smooth completion of the services provided to you, we may share your order information, account information, Device information and location information. For example, when you purchase products from CUUNION, we must share your personal information with logistics service providers to arrange delivery, or arrange partners to provide services. However, we only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and only share personal information necessary to provide services. Our partner third-party service providers are not authorized to use the shared personal information for any other purpose. Our partners include the following types:

* Suppliers of goods or services. We may share your personal information with suppliers, service providers and other partners who support our business, including supplying or providing technical infrastructure services to us, providing customer service, logistics and distribution services, payment services, data processing, etc. We share your personal information to enable the core shopping functionality of our products and/or services.

* Third-party merchants. In order to fulfill your need to purchase goods or services from third-party merchants and enable them to complete subsequent after-sales services to you, we must share your order information and necessary transaction-related information with third-party merchants.

* Partners who entrust us to promote. We may provide promotional services on behalf of other businesses to user groups using our products and/or services. However, we will only provide information on the reach and effectiveness of promotions to these partners, not your personally identifiable information, or we will aggregate this information so that it does not personally identify you. For example, we may provide partners with non-personally identifiable statistical information to help them understand their audience or customers.

For companies, organizations and individuals with whom we share your personal information, we will sign strict data protection agreements with them and require them to fill out a security questionnaire, in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures to process your personal information.

2. Transfer

We will not transfer your personal information to any companies, organizations and individuals, except in the following cases:

(1) Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties.

(2) When a merger, acquisition or bankruptcy liquidation is involved, if it involves the transfer of personal information, we will require new companies and organizations that hold your personal information to continue to be bound by this privacy policy, otherwise we will require the company or organization to continue to be bound by this privacy policy. Ask for your authorization again.

3. Public disclosure

We will only publicly disclose your personal information in the following circumstances:

(1) After obtaining your explicit consent.

(2) Disclosure based on law: We may publicly disclose your personal information under the mandatory requirements of laws, legal procedures, lawsuits or government authorities.

D. Retention Policy

We will retain personal information as long as it is necessary to achieve the purpose for which it was collected, or to comply with applicable laws or as required or permitted. As long as it can be reasonably inferred that retaining personal information will not achieve the purpose for which it was collected, we will no longer retain personal information, or will eliminate ways to associate personal information with a specific individual.

E. How we protect your personal information

1. We have used industry-standard security measures to protect the personal information you provide to prevent unauthorized access, public disclosure, use, modification, damage or loss of the data. We will take all reasonably practicable steps to protect your personal information. For example, when data (such as credit card information) is exchanged between your browser and the “service”, it is protected by SSL encryption; we also provide https secure browsing for CUUNION; we will use encryption technology to ensure the confidentiality of data; we We will use trusted protection mechanisms to prevent data from being maliciously attacked; we will deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we will hold security and privacy protection training courses to reinforce the importance of employees on protecting personal information awareness.

2. We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for as long as is necessary to achieve the purposes described in this policy, unless an extended retention period is required or permitted by law.

3. The Internet is not an absolutely secure environment, and emails, instant messaging, and communications with other users are not encrypted. We strongly recommend that you do not send personal information through such methods. Please use a complex password to help us keep your account secure.

4. In the event of an unfortunate personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and you can prevent and reduce the risk on your own. Advice on risks, remedies for you, etc. We will promptly notify you of the relevant information of the event by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to publish an announcement.

F. Your rights

In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we guarantee that you exercise the following rights over your personal information:

1. Access to your personal information

You have the right to access your personal information, subject to exceptions provided by laws and regulations. If you want to exercise your data access rights, you can do so yourself by:

(1) Account information: You can view or change your personal information through [Personal-Settings].

(2) Receipt information: You can add or modify your relevant information through [Personal-Address Management].

(3) Order information: Buyers can view all your order information through [Personal-My Order], including pending payment, pending delivery, pending delivery, and pending evaluation. You can choose to delete the completed order to delete your order information, but this may cause us to be unable to accurately judge your purchase information and to provide corresponding after-sales service.

2. Change of personal information

If you can log in to your account normally, you can change the password, mobile phone number, WeChat account and other information through [Personal-Settings-Mobile Phone/Modify Password/Wechat ID]. If you are unable to log in to your account, you can call the official customer service of CUUNION, and the customer service of CUUNION will inform you of the steps to change the relevant information after verifying the relevant personal information.

3. Delete your personal information

You may request us to delete personal information in the following circumstances:

(1) If our handling of personal information violates laws and regulations.

(2) If we collect and use your personal information without your consent.

(3) If our handling of personal information violates our agreement with you.

(4) If you no longer use our products or services, or you cancel your account.

(5) If we no longer provide you with products or services.

If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us and require them to delete it in a timely manner, unless otherwise required by laws and regulations, or these entities obtain your independent authorization.

When you delete information from our service, we may not delete the corresponding information from the backup system immediately, but will delete the information when the backup is updated.

4. Cancellation of promotional messages

(1) You can reply “[TD]” at any time to cancel the mobile phone promotional SMS we send to you.

(2) You can set whether to accept our push notifications, including products, promotional information, service information, etc. pushed to you through [Settings – CUUNION Strategy – Notifications].

5. Responding to your above request

If you are unable to change or delete your personal information through the methods disclosed in this Privacy Policy. In order to ensure security, you may need to provide a written request as required by CUUNION, or to prove your identity in other ways, and the written request can be sent to CUUNION customer service. We may ask you to verify your identity before processing your request.

G. How we handle children’s personal information

Our products, websites and services are primarily aimed at adults. Children may not create their own user accounts without the consent of their parents or guardians.

For the collection of children’s personal information with parental consent, we will only use or publicly disclose this information as permitted by law, expressly consented by a parent or guardian, or necessary to protect the child.

Although local laws and customs define children differently, we treat anyone under the age of 14 as a child.

If we discover that we have collected personal information from children without first obtaining verifiable parental consent, we will try to delete the data as soon as possible.

H. How your personal information is transferred globally

In principle, the personal information we collect and generate in the People’s Republic of China will be stored in the People’s Republic of China.

Since we provide products or services through resources and servers all over the world, this means that, after obtaining your authorization and consent, your personal information may be transferred to jurisdictions outside the country/region where you use the products or services, or subject to access from these jurisdictions.

Such jurisdictions may have different data protection laws or even no relevant laws. In such cases, we will ensure that your personal information is adequately and equally protected within the territory of the People’s Republic of China. For example, we may request your consent to transfer personal information across borders, or implement security measures such as data de-identification prior to cross-border data transfers.

I. How to update this policy

Our Privacy Policy is subject to change. We will not reduce your rights under this Privacy Policy without your express consent. We will post any changes to this policy on this page. For material changes, we will also provide a more prominent notice.

Material changes referred to in this policy include, but are not limited to:

1. Our service model has undergone major changes. Such as the purpose of processing personal information, the type of personal information processed, and the way in which personal information is used.

2. We have undergone major changes in ownership structure, organizational structure, etc. Such as business adjustments, bankruptcy mergers, etc. caused by changes in owners.

3. The main objects of personal information sharing, transfer or public disclosure have changed.

4. Your rights to participate in the processing of personal information and how to exercise it have undergone significant changes.

5. When there are changes to the responsible department, contact information and complaint channels that we are responsible for handling personal information security.

6. When the personal information security impact assessment report indicates that there is a high risk.

We will also archive older versions of this policy for your review.

J. Contact us

If you have any comments or questions about this Privacy Policy, or if you have any questions about the collection, use or disclosure of your personal information by CUUNION, please contact us via customer service/email.

Thank you for taking the time to read our Privacy Policy!

CUUNION