SeaPhone Privacy Policy

Preface

SeaPhone respects and protects the information of all users of the service (hereinafter referred to as "you" or "user"), and will protect user information and privacy security in accordance with laws and regulations and in accordance with industry best practices. We have developed this SeaPhone Privacy Policy (hereinafter referred to as "this Policy" or "this Privacy Policy") to help you understand the following:

1. How we collect and use your personal/business information
2. How we store your personal/business information
3. How we transfer and disclose your personal/business information
4. How we protect your personal/business information
5. Your rights to manage your personal/business information
6. Protection of personal information of minors
7. Changes and revisions to the Privacy Policy
8. How to contact us

Please read and understand this Privacy Policy carefully before using SeaPhone and related services, and use our products or services only after confirming that you fully understand and agree. Once you start to log in or use your SeaPhone account, it means that you have fully understood and agreed to this Policy, and agree that we collect, use, store and share your relevant information in accordance with this Privacy Policy. If you have any questions, comments or suggestions about the content of this Policy, you can contact us through the various contact methods provided in this Privacy Policy. This Privacy Policy is an integral part of the SeaPhone User Service Agreement.

1. How we collect and use your personal/business information

We will collect and use the information you actively provide when using SeaPhone and related services, as well as the information generated by you in the process of using functions or receiving services through automated means in the following ways:

1.1 Basic Business Functions

(1) When you register or log in to a SeaPhone account, SeaPhone will collect your personal/business information, including but not limited to mobile phone number, user name, etc. This information is collected to help you complete the SeaPhone account registration and protect your account security. If you refuse to provide this information, you may not be able to successfully register or log in to a SeaPhone account. After you register and log in to your account, you can choose to fill in user information (user profile, background image, user name, company name, region, etc.) according to your needs to complete your information. We will collect the user information you actively fill in for display to other users and provide you with information that interests you, including but not limited to sending you product and service information.

(2) When you use the identity authentication function or related services, in accordance with relevant laws and regulations, we may collect your real identity information (real name, company name, ID number, unified social credit code, telephone number, facial information, etc.) to complete the verification. In particular, if necessary, based on security considerations, in order to ensure that we provide services for you/your company, we may verify the information you provide and verify your identity through facial recognition. Some of this information is user sensitive information. You can refuse to provide it, but you may not be able to obtain related services, but it will not affect the normal use of other functions and services.

(3) In order to ensure the safe operation, quality and efficiency of the software and services, when you use SeaPhone related services or visit the SeaPhone platform webpage, we will collect your device's hardware model, operating system version number, device identifier, network device hardware address, IP address, browser type, language used, access date and time, WLAN access point, Bluetooth, base station, network access method, type, status, network quality data, operation, use, service logs and webpages you visit. We may associate your device information or phone number with your SeaPhone account.

(4) In order to analyze statistical indicators such as application additions, activations, retention, performance, etc., we may call the clipboard to perform attribution analysis on relevant statistical information. Please rest assured that during the statistical process, we will not transmit back other information you write to the clipboard and will not collect your privacy information.

(5) In order to prevent malicious programs, improve operational quality and efficiency, and protect account security, we will collect information about installed applications or running processes, the overall operation, usage and frequency of applications, application crashes, overall installation and usage, performance data, and application sources.

(6) In order to provide you with more thoughtful and comprehensive services, we will obtain your personal/business information from you or a third party through legal means.

(7) Message Notifications

You acknowledge and agree that we may send multiple types of notifications to one or more of the contact information (e.g., contact number) you provide during the use of SeaPhone and/or services for user message notification, identity verification, security verification, user experience research, dispute resolution, etc.

(8) Problem feedback

i. Customer service and problems: In order to facilitate contact with you, help you solve problems as soon as possible, or record the solutions and results of related problems, we may save your communication/call records and related content (including account information, feedback information, order information, other information you provide to prove relevant facts, or contact information you leave). If you consult, complain or provide suggestions for a specific order, we will use your account information and order information. In order to facilitate non-logged-in users to use customer service or feedback functions, we may associate the above information with your device information and can view it after logging in.

ii. When you complain about others or are complained by others, in order to protect the legitimate rights and interests of you and others, we may provide your account/identity information, contact information, and complaint-related content to consumer rights protection departments and regulatory authorities to promptly resolve complaints and disputes, except where such provision is expressly prohibited by laws and regulations.

iii. Questionnaire survey: In order to provide services and improve the quality of services, we may also use your other information, including the relevant information you provide when you contact customer service, and the questionnaire response information you send to us when you participate in the questionnaire survey; if you do not want to, you can also refuse to provide participation in the questionnaire survey.

1.2 Use of third parties in SeaPhone

In order to ensure the normal operation of SeaPhone or realize related functions, we may access services provided by third parties through SDK, API, plug-ins, etc. (see Appendix 1 for details). Before access, we will conduct strict security testing and privacy assessment on the third-party services, and agree with the third party on strict data protection measures to process your personal information in accordance with this Privacy Policy and any other relevant confidentiality and security measures to protect your privacy and user information security. These third-party service providers are independent information controllers and are solely responsible for their information collection and processing. We do not assume any responsibility for any disputes between you and third-party service providers.

1.3 Use of Cloud Number Service in SeaPhone

SeaPhone will provide you with Cloud Number Service in the form of SAAS service. You can choose the service you need according to your business needs. The Cloud Number Service referred to in this Agreement refers to the privacy protection service provided by SeaPhone to users through third-party service providers and basic telecommunications operators. The basic operator provides users with a temporary number (hereinafter referred to as "small number") and binds the small number to the user's commonly used mobile phone number to realize the function of answering calls and text messages through the small number). During your use of Cloud Number, SeaPhone will collect your personal/corporate information based on your operations and settings in the product, including but not limited to the business license information of the Cloud Number user, the name, ID card, mobile phone number, etc. of the legal person and agent. The mobile phone number, user name, and ID number bound to the cloud number; the text messages received and sent by the cloud number, the recordings of the calls made by the cloud number, etc. This information is collected to meet the national regulatory requirements for the legal use of the cloud number and to help you use the cloud number function more conveniently;

1.4 Use of Cookies and Similar Technologies

When you use SeaPhone and related services, we may use related technologies to send one or more cookies or anonymous identifiers to your device to collect, identify and store information when you visit and use this product. We promise not to use cookies for any other purpose other than the purposes described in this Privacy Policy. We use cookies and similar technologies mainly to achieve the following functions or services:

(1) Ensure the security, efficiency and operation of products and services

We may set authentication and security cookies or anonymous identifiers to confirm whether you have logged into the service safely or whether you have encountered theft, fraud or other illegal activities. These technologies will also help us improve service efficiency and increase login and response speed.

(2) Help you get a more relaxed access experience

Using such technologies can help you save the steps and processes of repeatedly filling in your personal/corporate information and entering search content (for example: recording searches, filling out forms).

(3) Recommend, display, and push content or accounts that may be of interest to you

We may use cookies and similar technologies to understand your preferences and usage habits, conduct data analysis, improve product services, recommend information or features that users are interested in, and optimize your choice of advertisements.

(4) Clearing cookies

Most browsers provide users with the function of clearing browser cache data. You can perform the corresponding data clearing operation in the browser settings function. If you clear it, due to these changes, you may not be able to use the SeaPhone services or corresponding features that we provide and rely on cookies.

1.5 Exceptions to obtaining authorization and consent

According to relevant laws and regulations, your personal/business information does not need to be authorized and consented in advance in the following circumstances:

(1) related to national security and national defense security;

(2) related to public security, public health, and major public interests;

(3) related to criminal investigation, prosecution, trial, and execution of judgments;

(4) for the purpose of protecting your or others' life, property and other major legal rights and interests, but it is difficult to obtain your authorization and consent;

(5) personal/business information that you disclose to the public on your own;

(6) personal/business information collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;

(7) necessary for maintaining the safe and stable operation of SeaPhone and related services, such as discovering and handling software and related service failures;

(8) When it is necessary for academic research institutions to conduct statistical or academic research based on public interests and to provide academic research or description results to the outside, the personal/corporate information contained in the results shall be de-identified;

(9) Keyword information you enter when using the search service provided by SeaPhone;

(10) Information data collected by SeaPhone that you publish on SeaPhone, including but not limited to participation in activities, transaction information and evaluation details;

(11) Your violation of legal provisions or SeaPhone rules and the measures SeaPhone has taken against you.

(12) Other third partiesWhen providing services to you through SeaPhone webpage or client, the information you provide to third parties is not subject to this Privacy Policy.

(13) Other circumstances stipulated by laws and regulations.

Please note that if the information cannot identify your personal/corporate identity alone or in combination with other information, it does not belong to your personal/corporate information in the legal sense; when your information can identify your personal/corporate identity alone or in combination with other information or when we use data that cannot be linked to any specific personal/corporate information in combination with other personal/corporate information of yours, such information will be treated and protected as your personal/corporate information in accordance with this Privacy Policy during the period of combined use.

2. How we store your personal/corporate information

The personal/corporate information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. If it is necessary to transfer the relevant personal/corporate information collected within the territory to overseas institutions in order to handle cross-border business, we will do so in accordance with the relevant applicable laws, administrative regulations and regulations of relevant regulatory authorities. We will ensure that your personal/business information is adequately protected, such as anonymization, encrypted storage, etc. We only store your personal/business information for the period necessary for the purpose of providing SeaPhone related services and within the time limit required by laws and regulations.

3. How do we transfer, share, and disclose your personal/business information

3.1 Transfer

As our business continues to develop, we may conduct mergers, acquisitions, asset transfers, or other similar transactions, and your personal/business information may be transferred as a result. In the event of the aforementioned changes, we will require the successor to continue to be bound by this Privacy Policy in accordance with laws and regulations and security standards no less stringent than those set forth in this Privacy Policy. If the successor changes the original processing purpose or processing method, we will require the successor to obtain your authorization and consent again.

3.2 Sharing

(1) When our affiliates provide services to you or us, we may share your personal/business information with our affiliates. However, we only share necessary personal/business information, and the processing of your information by the affiliates is subject to this Privacy Policy. If the affiliates want to change the purpose of processing your personal/business information, they will ask for your authorization and consent again.

(2) In order to provide you with comprehensive and thoughtful services, we will share your personal/business information (including the platform account you added, organization, permissions, etc.) with third-party advertisers, application developers, open platforms or other partners with your explicit authorization.

3.3 Disclosure

Protecting user information security is a basic policy of SeaPhone. We will not disclose your personal/business information. However, the following circumstances are excluded:

(1) Your explicit consent has been obtained;

(2) It is necessary to conclude and perform a contract to which you are a party, or to implement human resources management in accordance with labor rules and regulations formulated in accordance with the law and collective contracts signed in accordance with the law;

(3) It is necessary to perform statutory duties or obligations;

(4) It is necessary to respond to public health emergencies, or to protect the life, health and property safety of natural persons in emergency situations;

(5) To carry out news reporting, public opinion supervision and other activities for the public interest, and process your personal/corporate information within a reasonable scope;

(6) Other circumstances stipulated by laws and administrative regulations.

Even in the above circumstances, we will use legal and legitimate methods and process your personal/corporate information for clear and reasonable purposes.

4. How we protect your personal/business information

4.1 We attach great importance to the security of your personal/business information and will strive to take reasonable security measures (including technical and management aspects) to protect your personal/business information. SeaPhone has a security protection function for user accounts, and uses security measures such as encrypting user passwords to prevent the personal/business information you provide from being improperly used or accessed, disclosed, used, modified, damaged, lost or leaked without authorization.

4.2 We will use encryption technology, anonymization processing and related reasonable and feasible means that are no less than those of our peers in the industry to protect your personal/business information, and use security protection mechanisms to prevent your personal/business information from being maliciously attacked.

4.3 We will establish a special security department, security management system, and data security process to ensure the security of your personal/business information. We adopt a strict data use and access system to ensure that only authorized personnel can access your personal/business information, and conduct security audits on data and technology in a timely manner.

4.4 Although the above reasonable and effective measures have been taken and the standards required by relevant laws and regulations have been complied with, please understand that due to technical limitations and various possible malicious means, in the Internet industry, even if you do your best to strengthen security measures, it is impossible to always guarantee 100% security of information. We will try our best to ensure the security of the personal/corporate information you provide to us. We do not assume any responsibility for information security issues that are not caused by us.

4.5 You know and understand that the system and communication network you use to access our services may have problems due to factors beyond our control. Therefore, we strongly recommend that you take active measures to protect the security of your personal/corporate information, including but not limited to using complex passwords, changing passwords regularly, and not disclosing your account password and related personal/corporate information to others. We do not assume any responsibility for password leakage or loss caused by your personal reasons.

4.6 We will formulate emergency response plans and immediately activate emergency response plans when user information security incidents occur, and strive to prevent the impact and consequences of these security incidents from expanding. Once a user information security incident (leakage, loss) occurs, 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, suggestions for you to prevent and reduce risks on your own, and your remedial measures. We will promptly inform you of the relevant situation of the incident by push notification, email, letter, SMS and related forms. When it is difficult to inform you one by one, we will take reasonable and effective means to issue an announcement. At the same time, we will also report the disposal of the user information security incident in accordance with the requirements of the relevant regulatory authorities.

5. Your right to manage personal/business information

During your use of SeaPhone and related services, you may access and manage your personal/business information in the following ways:

5.1 Access and management of personal/business information

(1) You can log in to your SeaPhone account to query, access, correct, and delete your personal/business information, including user name, contact number, and user-entered third-party platform account/password (such as e-commerce platform, social platform, etc.). Please note that for security and identity reasons, you may not be able to modify certain initial information (including business license, ID number, etc. used for real-name authentication) on your own. If you really need to modify such information, please contact us according to the contact information specified in this Privacy Policy.

(2) You have the right to request SeaPhone to delete your personal/business information when the following circumstances occur:

i. The purpose of processing has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose of processing;

ii. We stop providing products or services, or the retention period has expired;

iii. The individual/business withdraws consent;

iv. Our processing of personal/business information violates laws, administrative regulations or agreements with you;

v. Other circumstances stipulated by laws and administrative regulations.

Personal/business information deletion: refers to the act of removing personal/business information from systems involved in implementing daily business functions, so that it remains inaccessible and cannot be retrieved. After you or we assist you in deleting the relevant information, due to applicable laws and security technology restrictions, we may not be able to immediately delete the corresponding information from the backup system. We will securely store your personal/business information and limit any further processing of it until the backup can be cleared or anonymized.

5.2 Cancelling Your Account

You can apply to SeaPhone to cancel your account at any time. Before you cancel your account, we will verify your personal/corporate identity, security status, device information, etc. We will process your application promptly after receiving it and respond to your request within 15 working days or the time limit required by laws and regulations. You know and understand that canceling your account is irreversible. When you cancel your account, all content, information, data, and records under your account will be deleted or anonymized, and you will no longer be able to retrieve, access, obtain, continue to use and retrieve them, and you have no right to ask us to retrieve them, except as otherwise provided by laws and regulations and relevant national standards.

If you still decide to cancel your SeaPhone account after careful consideration, please be sure to carefully read and fully understand the SeaPhone account cancellation instructions first. If you need to use our services again after cancellation, you are welcome to re-register using your mobile phone number.

6. Protection of Minors' Personal Information

6.1 If you are a minor under the age of 18, you should read and agree to this Privacy Policy under the supervision and guidance of your parents or other guardians before using this product. If you are the guardian of a minor under the age of 18, you should read and agree to this Privacy Policy for your ward before using SeaPhone and related services.

6.2 If you are the guardian of a minor, if you have other questions about the personal information of the minor you are protecting, please contact us through the contact information published in this Privacy Policy.

7. Changes and revisions to the privacy policy

7.1 In order to provide you with better services, SeaPhone and related services will be updated and changed from time to time. We will revise this privacy policy from time to time. These revisions will constitute part of this privacy policy and have the same effect as this privacy policy. Without your explicit consent, we will not reduce your rights under this privacy policy currently in effect.

7.2 After this privacy policy is updated, we will issue an updated version on SeaPhone and remind you through system announcements, notifications or other methods that SeaPhone deems appropriate. When you use SeaPhone and related services, you should promptly check and understand the modified content so that you can keep up to date with the latest version of this privacy policy.

8. Dispute resolution

If you have any dispute with SeaPhone, the dispute shall be resolved in accordance with the provisions of the SeaPhone User Service Agreement.

9. How to contact us

9.1 If you find that your personal/corporate information has been leaked, especially if your SeaPhone username and password have been leaked, please contact SeaPhone customer service immediately so that SeaPhone can take appropriate measures.

9.2 If you have any questions, comments, suggestions or complaints about our privacy policy and the handling of your personal/corporate information, please contact us through the official website. We will generally respond to your feedback within 15 days.