The "EasyLink User Privacy Policy" applies to all products and services (collectively referred to as "Services") provided by HYPERGAME TECHNOLOGY LIMITED (hereinafter referred to as "we", "us", or "our"). When you use EasyLink's Services, EasyLink will collect, use, store, and process your relevant information.
EasyLink fully understands the importance of personal information to you and will make every effort to protect the security of your personal information. EasyLink will adhere to the principles of lawfulness, fairness, and necessity, and will collect, use, and process your personal information and privacy in accordance with this Privacy Policy. Through this Privacy Policy, you will learn about the following:
I. Information We Collect
II. How We Use Your Personal Information
III. How We Use Cookies and Similar Technologies
IV. How We Share, Transfer, and Publicly Disclose Your Personal Information
V. How We Store and Protect Your Personal Information
VI. Your Rights
VII. How We Protect Minors' Personal Information
VIII. How to Contact Us
IX. How This Policy is Updated
I. Information We Collect
During your use of EasyLink Services, EasyLink will collect information you actively provide or generated through your use of the Services in the following ways, in order to provide and optimize our Services and ensure the security of your account:
1. When you register for or use EasyLink Services, we will collect your network identity identifier information and personal commonly used device information to mark you as a EasyLink user. If you use a third-party account (such as WeChat, QQ, etc.) to log in to EasyLink, we will collect your unique identifier, avatar, and nickname from the third party to save your login information, allowing you to log in on different devices.
2. To ensure your normal use of our Services, maintain the basic functions of the service, optimize product performance, enhance your experience, and ensure the security of your account, we will perform characteristic analysis and user profiling based on the collected information regarding your preferences, habits, and location, in order to provide you with more suitable customized services. For example, showing or recommending search results, cloud computer content, offline events, information feeds, or advertising/promotional results that are more relevant to you (rather than general push notifications). To this end, the information we need to collect includes your device information, including device hardware serial number, device name, device type and version, android ID, system version, IP address, location, local phone number, contacts, device unique identifier, device MAC address, OID, IMEI, IMSI, application ID, network type, images, audio/video, and SMS, software list. The following permissions are required: location, access to phone information, read/write phone storage, persistent notifications, display overlay windows.
3. In addition to the above information, to improve service quality, we may also collect other information from you, such as information you provide when contacting our customer service team (e.g., EasyLink ID, third-party payment account), and information provided when you participate in our promotional activities (e.g., real name, shipping address).
4. During the operation of the APP, to implement relevant functions and meet your needs as well as the needs of other users, we may integrate the following third-party SDKs. You acknowledge and agree that, in certain specific business scenarios, to improve business processing capacity, reduce costs, or for other considerations, we may use capable third-party location SDKs to obtain your relevant information, for example, using the "Tencent Location" SDK to obtain your IMEI information. However, we will not proactively transmit the aforementioned information to such third parties without your consent. The following is the list of SDKs:
4.1 Bugly SDK
Function: Completes error log reporting to facilitate timely optimizations for a better user experience.
Information collected: Phone status, network status, reading logs.
5. To provide you with security protection, we collect, use, or integrate your account information, transaction information, device information, log information, and information shared by EasyLink with your authorization or based on legal requirements, to comprehensively assess your account and transaction risks, perform identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures according to law.
II. How We Use Your Personal Information
1. We will use the aforementioned collected information for the following purposes. If we need to collect and/or use your personal information for other purposes, we will seek your separate consent:
Assisting you in registering for a EasyLink account: To facilitate our provision of services to you, you need to provide true, complete, accurate, and valid personal identity information and other relevant information to complete the registration of a real-name account.
Providing services to you: To provide you with services, or to provide you with a better service experience, we will collect and use your necessary personal information.
Product development and service optimization: During product development and service optimization, your information may be used to analyze failure causes, analyze user needs, and carry out product upgrades. Your information from a specific service may be used in other services provided by EasyLink to improve related services.
Sending you notifications:
Service Information: EasyLink may use your information, such as device information and order information, to extract your browsing preferences, behavior patterns, etc., and push advertisements or information related to EasyLink services to you via email, SMS, notifications, etc.
System Announcements: When necessary (e.g., when EasyLink services require maintenance, changes, suspension, or termination), we will use the information you provided to send you system announcements.
Providing you with security protection: To ensure the security of your account, we may use your information for real-name authentication, identity verification, security precautions, transaction risk prevention, anti-fraud monitoring, archiving and backup, customer service, etc. During this process, we may provide your information to third parties to the extent necessary to achieve the aforementioned purposes and require such third parties to comply with the provisions of this Privacy Policy.
2. According to relevant laws and regulations, your consent is not required for the collection and/or use of your information in the following circumstances:
When related to national security and national defense;
When related to public security, public health, or significant public interests;
When related to criminal investigation, prosecution, trial, and execution of judgments;
When it is necessary to protect the vital legitimate rights and interests of the information subject or another individual, such as life or property, and it is difficult to obtain your consent;
When the information collected is already disclosed to the public by yourself;
When the information is collected from legally publicly disclosed information, such as legal news reports, government information disclosure, etc.;
When necessary for signing a contract at your request;
When necessary for maintaining the safe and stable operation of our services, such as detecting and handling service failures;
When necessary for legitimate news reporting;
When it is necessary for academic research institutions to carry out statistics or academic research based on the public interest, and when providing the results of academic research or descriptions externally, the information contained in the results is de-identified;
Other circumstances stipulated by laws and regulations.
III. How We Use Cookies and Similar Technologies
1. When you use our products and/or services, we may use cookies and similar technologies to collect some of your personal information, including: your website browsing habits, browsing information, and login information. Cookies and similar technologies collect this type of information to facilitate your use of our products and/or services, simplify your repeated operations (such as registration, login), facilitate viewing of your usage history (such as video viewing history), provide you with service content that better meets your personal needs and content you may be more interested in, protect your information and account security, and improve our products and services.
2. If you refuse our use of cookies and similar technologies to collect and use your relevant information, you can manage, (partially/fully) reject cookies and/or similar technologies through your browser settings, provided your browser has this functionality; or delete cookies and/or similar technologies already stored on your computer, mobile device, or other device, thereby preventing us from fully or partially tracking your personal information. If you need detailed information on how to change browser settings, please refer to the relevant settings page of the browser you are using. You understand and acknowledge: Some of our products/services can only be realized through the use of cookies or similar technologies. If you refuse to use or delete them, you may not be able to use our related products and/or services normally or obtain the best service experience through our products and/or services, which may also have a certain impact on your information protection and account security.
IV. How We Share, Transfer, and Publicly Disclose Your Personal Information
(A) Sharing
We will not share your personal information with any other company, organization, or individual, except in the following circumstances:
1. Sharing with explicit consent: After obtaining your explicit consent, we may share your personal information with other parties.
2. We may share your personal information externally in accordance with laws and regulations, or as required by mandatory requirements of competent government authorities.
3. Sharing with our affiliated companies: Your personal information may be shared with our affiliated companies. We will only share necessary personal information and it will be subject to the purposes stated in this Privacy Policy. If an affiliated company changes the purpose of processing personal information, it will seek your authorization and consent again.
4. Sharing with authorized partners: To achieve the purposes stated in this Privacy Policy, some of our services may be provided by authorized partners. We may share some of your personal information with partners to provide better customer service and user experience. For example, companies we engage to provide third-party data statistics and analysis services may need to collect and access personal data for data statistics and analysis. In such cases, these companies must comply with our data privacy and security requirements. We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and will only share the personal information necessary to provide the service.
For companies, organizations, and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to process personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.
5. Sharing your information is necessary to provide you with the services you need or to handle disputes or conflicts between you and others.
6. To achieve the purposes described in Article I of this Privacy Policy, "How We Collect and Use Your Personal Information."
7. To fulfill our obligations under this Privacy Policy or other agreements we have reached with you and to exercise our rights.
(B) Transfer
We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:
1. Transfer with explicit consent: After obtaining your explicit consent, we may transfer your personal information to other parties;
2. In the event of a merger, acquisition, or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy; otherwise, we will require that company/organization to seek your authorization and consent again.
(C) 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: In cases required by law, legal proceedings, litigation, or mandatory requirements of competent government authorities, we may publicly disclose your personal information.
(D) Exceptions to Obtaining Prior Authorization for Sharing, Transfer, and Disclosure
In the following circumstances, sharing, transferring, or disclosing your information does not require your prior authorization and consent:
1. When related to national security and national defense;
2. When related to public security, public health, or significant public interests;
3. When related to criminal investigation, prosecution, trial, and execution of judgments or other judicial or administrative enforcement actions;
4. When it is necessary to protect the vital legitimate rights and interests of you or another individual, such as life or property, and it is difficult to obtain your consent;
5. Information you have already disclosed to the public;
6. When the information is collected from legally publicly disclosed information, such as legal news reports, government information disclosure, etc.
According to legal provisions, the sharing and transfer of de-identified information, where the data recipient cannot restore and re-identify the information subject, does not constitute external sharing, transfer, or public disclosure of personal information. The storage and processing of such data will not require further notification to you or obtaining your consent.
V. How We Store and Protect Your Information
1. Information Storage
1.1 Storage Location: In accordance with legal and regulatory requirements, we will only store the collected personal information about you within the territory of the People's Republic of China. Currently, we do not have any scenarios requiring cross-border storage of your personal information or provision of your personal information to overseas entities. If cross-border data transmission is indeed necessary, we will separately inform you clearly (including the purpose of data export, recipient, method and scope of use, content used, security measures, security risks, etc.) and obtain your authorized consent. We will ensure that the data recipient has adequate data protection capabilities to protect your personal information.
1.2 Storage Period: We retain your personal information for the shortest period necessary to provide you with the products and services and fulfill their purposes. For example, when you use our registration and account functions, we need to collect your mobile phone number. After you provide it and during the period you use this function, we need to continuously retain your mobile phone number to provide you with this function normally and ensure the security of your account and system. Additionally, we may retain your relevant information for the period necessary as required by relevant laws.
1.3 After the aforementioned storage period expires, we will delete or anonymize your personal information.
2. Information Protection
2.1 The security of your personal information is crucial to us. We will strictly comply with relevant laws and regulations and adopt reasonably feasible measures recognized within the industry to protect your personal information, preventing unauthorized access, disclosure, use, modification, damage, or loss of information.
2.2 We use industry-standard security measures to protect the personal information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data. We will take all reasonably practicable measures to protect your personal information. For example, using SSL to encrypt data protection; we have established access control mechanisms to ensure only authorized personnel can access personal information; we conduct regular security and privacy protection training sessions to enhance employee awareness of the importance of protecting personal information.
2.3 The internet is not an absolutely secure environment, and communication methods such as email and instant messaging are not encrypted. We strongly advise you not to send personal information through such methods. Please properly protect your personal information. You must maintain the confidentiality of your account and password. In any case, please handle them with care. If you discover that your personal information has been leaked, especially your account and password, please contact EasyLink customer service immediately so that EasyLink can take appropriate measures. Please use complex passwords to help us ensure the security of your account.
VI. Your Rights
1. Managing Your Personal Information: You have the right to access, update, correct, and delete your personal information while using our services. We provide corresponding operation settings within specific services for you to perform these actions. When you access, update, correct, and/or delete your personal information, we may require identity verification to ensure information security. You understand that when you delete or correct information, we may not immediately correct or delete the corresponding information from our backup systems, but we will correct or delete such information when the backup is updated.
2. Sharing Your Personal Information: You can share your personal information with third parties through our services. Please note that as long as you do not delete publicly posted information, it will remain in the public domain; even after you delete shared information, it may still be cached, collected, copied, or provided to the public by third parties. Please carefully consider disclosing your personal information, especially sensitive personal information (such as your race, religion, personal health and medical information, identification documents, personal biometric information, property information, whereabouts, information of minors). You can use our relevant settings (if any) to control the scope of information you share. If you disclose your personal information through the aforementioned channels, we shall not be liable for any leakage of your information or any harm to you or others resulting from such disclosure.
3. Requesting Correction or Deletion of Your Personal Information:
If you find that the personal information we hold about you is inaccurate, you may request that we correct it.
If you find that our processing of your personal information violates laws and regulations, our agreement, this Privacy Policy, or if you no longer use our services or have cancelled your account, you may request that we delete your personal information.
You understand that, due to mandatory provisions of relevant laws and regulations, we may not be able to respond to your specific request for deletion of information.
You understand that after some or all of your personal information is deleted, related services provided by us, or corresponding parts thereof, may become unavailable.
4. Changing the Scope of Your Authorization: You can change the scope of personal information you authorize us to collect, use, and store through the channels and methods we publish. When you withdraw your authorization, we will no longer be able to provide you with the services corresponding to the withdrawn authorization and will no longer process your corresponding information. However, your decision to withdraw your consent will not affect the processing of personal information carried out based on your prior authorization.
5. Account Cancellation: You can cancel your account according to our operating instructions. After the account is cancelled, we will stop providing you with services and delete your personal information upon your request, unless otherwise provided by laws and regulations.
VII. How We Protect Minors' Personal Information
1. Minors should obtain the consent of their guardians before using our products and services. If you are a minor, before using our products and services, you should read this Privacy Policy together with your guardian under their supervision and guidance, and use our products and services and submit personal information only with the explicit consent and guidance of your guardian. We protect the personal information of minors in accordance with relevant national laws and regulations. We will only collect, use, or publicly disclose minors' personal information when permitted by laws and regulations, with the explicit consent of the guardian, or as necessary to protect the rights and interests of the minor.
2. If you are a guardian of a minor and have questions regarding the personal information of the minor under your guardianship, you can contact us through the contact information provided in Article VIII "Contact Us" of this Privacy Policy to resolve the issue. If we discover that we have collected personal information from a minor without verifiable prior parental consent, we will delete the relevant data as soon as possible.
VIII. How to Contact Us
If you have any questions, comments, or suggestions regarding this Privacy Policy, please contact us through the following method:
Email:cloudsupport@kaijia.com
IX. How This Policy is Updated
1. We may update this Privacy Policy from time to time and publish the changes through announcements, etc. If there are changes that materially reduce your rights, we will inform you through reasonable means, such as prominent notices on the page, sending emails to you.
2. If you continue to use our services, it will be deemed that you agree to the updated Privacy Policy.