ITNIO TECH Privacy Policy

ITNIO TECH respects and protects user information and will treat such information with great diligence and care. When you use the services provided by our website, we will collect, process and disclose your information in accordance with this Privacy Policy. Please read this Privacy Policy carefully and confirm that you have read and understood this Privacy Policy. Please pay particular attention to the contents in bold in this Privacy Policy and be sure to understand our rules for handling your and/or your users information.

Before registering, browsing or using ITNIO TECH services, if you confirm acceptance of this Privacy Policy or continue to use the Services by checking popover, "Agree" button or any other means of your own choice, you shall be deemed to have carefully read, fully understood and accepted all contents of these Terms, especially the terms of limitation or exemption from liability and dispute jurisdiction terms. Such terms will be highlighted in bold and/or underlined for your attention. This policy applies to all products and services provided by ITNIO TECH.

1. Scope of application

1.1 This Privacy Policy applies to all services of ITNIO TECH website, including providing you with page browsing, website login services and technical services provided to you through the ITNIO TECH website or by ITNIO TECH technicians through channels other than the official website.

1.2 Our services may contain links to third party websites, applications or services, and this Privacy Policy does not apply to any products, services, websites or content provided by third parties. The Website may contain links and instructions to websites owned or operated by third party vendors and other third parties " external websites "). We are not responsible for the validity of external websites or the content of any external websites. If you have any questions about the link or the content on the external site, please contact the administrator of the external site. Any external sites provided by this site are for your convenience only. The inclusion of any links or instructions on this site does not imply an endorsement of the external site.

1.3 If you use our services to provide services for your users, since your business data belongs to you, you shall agree a separate privacy policy with your users.

2. Collection and use of user information

2.1 User Information Collection

2.1.1 When you create an account on the ITNIO TECH website, you are required to submit true, legal and valid information. Information to be submitted includes, but is not limited to: The basic personal information of the user name, email, mobile phone number, mailing address, etc.), Basic enterprise information of the user company name, business license, unified social credit code), name of the user's legal representative, information of the user's handler including name, mobile phone number, email address, ID number), and bank account information of the user including bank, account number, account name, registered address and registered telephone number); For the purpose of real-name authentication, the user agrees and authorizes us to provide, inquire and check the aforementioned information of the user to the relevant identity authentication authorities such as personal credit bureaus, government departments, etc.) by ourselves or by a third party.

2.1.2 You shall complete the real-name authentication of your account in accordance with the Network Security Law of the People's Republic of China, and you shall provide us with your registered email address and set and confirm your login password. The registered email address and mobile phone number provided by you will be used for your registration, login, binding account, and password retrieval to receive verification code, as well as the contact information specified by you and ITNIO TECH Cloud to receive relevant business notifications such as service changes). ITNIO TECH may use your contact information to send you business notices including billing), advertise products, promote marketing or communicate with you.

2.1.3 When you visit the Website, part of your personal information such as name, date of birth, personal ID number, address, telephone number, email address, occupation, education background, work experience and other relevant information) provided by you will be collected, and part of your information not provided by you will be collected, such as: Browser type, domain name, IP address, web pages visited and time spent browsing using different technologies and methods, including: IP address, Cookies, Internet labels and collection of browsing data. In order to improve the quality of our service, we need your personal information to fulfill your personal needs and provide better service. We reserve the right to take measures to verify the accuracy of the information you provide. If the information you provide is other people's personal information, we will assume that you have obtained their permission. The transmission of information from the website may not be confidential, so the information you send may be read or intercepted by others.

2.1.4 When you use the services provided by our website, we will automatically collect your detailed usage of our services and save it as the relevant network log. Examples include the content of your search query, the IP address, the type of browser, the carrier, the language used, the date and time of access, and the web pages you visited.

2.1.5 Please note that individual equipment information and log information cannot identify the identity of a specific natural person. If we use such non-personal information in combination with other information to identify specific natural persons, or use it in combination with personal information, such non-personal information shall be deemed as personal information during the period of such combined use, unless authorized by you or otherwise provided by laws and regulations, We will anonymize such personal information through technical processing of personal information, so that it cannot identify or associate with your process without the help of additional information).

2.1.6 ITNIO TECH will record and analyze the user's consultation records, handicap records and troubleshooting process such as communication records) generated by your use of ITNIO TECH services in order to respond to your help requests in a timely manner and improve the service.

2.2 Use of user information collection

2.2.1 In order to provide you with the product or service real-name authentication information and the mobile phone number used to receive the verification code are the premise of continuing to obtain the service);

2.2.2 For the purpose of maintaining and improving the product or service such as the mobile phone and email of the business contact submitted by you for receiving business notifications and communication);

2.2.3 We may design, develop and promote new products and services on the basis of user information statistics; We keep statistics on our service usage and may share these statistics with the public or third parties, but these statistics do not contain any identifying information about you

2.2.4 Promote and introduce products to you under the premise of laws and regulations;

2.2.5 In order to improve the security of your use of the services provided by us, our affiliates and partners, protect you or other users or the public from personal and property safety infringement, and better prevent phishing websites, fraud, network loopholes, computer viruses, network attacks, network intrusion and other security risks, To more accurately identify violations of laws and regulations or related agreements and rules of ITNIO TECH, we may use your account information and integrate device information, related network logs and information shared by our affiliates and partners to judge your account and transaction risks, conduct identity authentication, and detect and prevent security events. And take necessary measures to record, audit, analyze and dispose according to law;

2.2.6 Other circumstances approved by you.

2.3 Collection of sensitive personal information

Sensitive personal information refers to the personal information that, once leaked or illegally used, is likely to cause the personal dignity of natural persons to be infringed or the personal and property safety to be jeopardized. The above information provided by users or collected by us may contain sensitive personal information, such as ID card number, personal biometric information static or dynamic), bank account number. Please be careful and pay attention to sensitive personal information. Users agree that we may handle sensitive personal information according to the purpose and manner stated in this Policy.

2.4 If you are located in the mainland of the People's Republic of China, the personal information we collect about you in accordance with this Policy will be stored in the People's Republic of China. If it is necessary to provide personal information outside the People's Republic of China due to business needs, we will transmit the information according to the requirements of relevant laws and regulations of the People's Republic of China.

3. How do we use cookies and related technologies

3.1 We may collect and use your information through cookies and other relevant technologies. Specific purposes for which we use cookies include:

3.1.1 Remember your identity. For example, cookies help us identify you as our registered user.

3.1.2 Analyze your use of our services so as to provide you with more thoughtful and personalized services, including but not limited to customized pages, recommendations, etc.

3.2 You can set the browser to reject or manage cookies. However, please note that if cookies are disabled, you may not enjoy a quality service experience and the availability of certain functions may be affected.

3.3 We do not use Cookies for any purpose other than the purpose stated in this Privacy Policy.

4. Sharing, transfer and public disclosure of user information

4.1 We will not share your user information with other organizations and individuals, except in the following cases:

4.1.1 After obtaining your express consent, we will share your user information with other parties;

4.1.2 We may share your user information in accordance with laws and regulations, litigation and arbitration, or as required by administrative and judicial authorities according to law;

4.1.3 Sharing with Affiliates: Your user information may be shared with our affiliates. We will only share such user information as is necessary to provide the services, subject to the purposes stated in this Privacy Policy. If the Affiliate wishes to change the purpose of processing user information, it will again seek your authorization and consent.

4.1.4 We may entrust trusted partners to provide services, so we may share some of your user information with partners in order to provide better customer service and optimize user experience. We will only share your user information for legal, legitimate, necessary, specific and explicit purposes, and only share the user information necessary to provide the service. Our partners have no right to use shared user information for any other purpose. Currently, our authorized partners include the following types: suppliers, service providers and other partners. We send information to suppliers, service providers and other partners who support our business, including providing user authentication services, basic technical services, providing consulting, analysis and other professional services. For the companies, organizations and individuals with whom we share user information, we will sign strict confidentiality agreements or agree in the confidentiality clauses of the agreements, requiring them to process user information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

4.15 If you are located in the mainland of the People's Republic of China, according to the provisions of the Personal Information Protection Law of the People's Republic of China, unless authorized and consented by users, we will not share users' personal information with any third party other than our affiliated companies, except that specific individuals cannot be identified after processing and cannot be recovered.

4.2 We will not transfer your user information to any company, organization or individual, except in the following cases:

4.2.1 After obtaining your express consent, we will transfer your user information to other parties;

4.2.2 In the event of a merger, acquisition or bankruptcy liquidation between ITNIO TECH and other legal entities, or other circumstances involving merger, acquisition or bankruptcy liquidation, such as the transfer of user information, we will require the new companies and organizations holding your user information to continue to be bound by this Policy. Otherwise, we will require the company, organization and individual to seek permission from you again.

4.3 We will only publicly disclose your user information under the following circumstances:

4.3.1 We may publicly disclose your user information with your express consent or at your choice;

4.3.2 In order to protect the personal and property safety of ITNIO TECH and its affiliated users or the public, we may disclose your user information in accordance with applicable laws or relevant agreements and rules of ITNIO TECH.

4.4 According to the provisions and requirements of the law, it is not necessary to obtain your authorization in advance to share, transfer or publicly disclose your user information under the following circumstances:

4.4.1 Those related to national security and national defense security;

4.4.2 Those related to public safety, public health and major public interests;

4.4.3 Those related to criminal investigation, prosecution, trial and execution of judgment;

4.4.4 In order to protect your or other individuals' life, property and other major legal rights and interests, but it is difficult to get the consent of the person;

4.4.5 Personal information disclosed by you to the public;

4.4.6 Relevant to your performance of obligations stipulated by laws and regulations;

4.4.7 Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

5. User business data

5.1 The business data that you analyze, process, store, upload, download, distribute and otherwise process during the use of ITNIO TECH services shall be your user business data. As a service provider, ITNIO TECH will only process your business data in strict accordance with your instructions and will not make any unauthorized use or disclosure of your business data except as required by consensus with you or in accordance with specific laws and regulations.

5.2 ITNIO TECH urges you to exercise caution in judging the legality of the source and content of user's business data: You shall ensure that User's business data is collected and used according to law, and you do not and have not infringed the legal rights of any individual or entity in any way. You understand and agree that China and other countries and regions may have relevant regulations on data storage and exit, and that you shall be solely responsible for all results and responsibilities arising out of any violation of laws, regulations, departmental rules or national policies by the source, content or processing of your users' business data.

6. Management of user information

6.1 You can access, modify, and delete your user information. In order to protect the security and legal rights of your account, different information access, modification and deletion may have different requirements. In addition, some of your information may not be accessible, modified or deleted for example, you cannot obtain the ID of your registered account) based on technical logic, legal and regulatory requirements, information security and other legitimate reasons.

6.2 If you want to change the real-name authentication information of your ITNIO TECH account, you need to contact ITNIO TECH by phone or email and follow our requirements.

6.3 Under the following circumstances, you may request us to delete user information:

6.3.1 If we process user information in violation of laws and regulations;

6.3.2 If we collect or use your user information without your express consent;

6.3.3 If our behavior of processing personal information seriously violates the agreement with you; We may ask you to verify your identity first you may6.4 You can cancel your registered account. After successful cancellation, we will stop providing you with products or services, and all services and data under this account will be deleted and cannot be recovered. In addition, we will delete your personal information or anonymize it upon your request, unless otherwise stipulated by laws and regulations.

7. Safety and security of user information

7.1 ITNIO TECH attaches great importance to your information security. We endeavor to take all reasonable physical, electronic and administrative security measures to protect your User information from unauthorized access, public disclosure, use, modification, damage or loss of User information. We will use encryption technology to improve the security of user information; We use trusted protection mechanisms to prevent malicious attacks on user information; We deploy access control mechanisms to try to ensure that only authorized personnel have access to user information.

7.2 Please use a complex password and keep it safe to ensure the security of your account. We will do our best to ensure the security of any information you send us. Furthermore, we take reasonable and practicable steps to avoid collecting irrelevant user information. We will only retain your User information for as long as necessary to achieve the purposes stated in the Cost Policy, unless it is necessary to extend the retention period or permitted by law. After the above user information retention period, we will delete or anonymize your personal information.

7.3 In order to improve the security of users in using our services and protect the personal and property safety of users or the public from infringement, we use or integrate users' registration information, device information, network logs, as well as users' frequency of using applications, crash data, overall usage, performance data and sources of applications. To comprehensively judge user account and transaction risks, identity authentication, detection and prevention of security incidents, and according to the law to take the necessary record, audit, analysis, disposal measures.

7.4 Due to technical limitations and possible malicious means, it is impossible to guarantee 100% security of information all the time, even if we do our best to strengthen security measures. The systems and communication networks you use to access our services may become problematic due to factors beyond our control. In the event of an unfortunate user information security incident leakage, loss, etc.), we will inform you in a timely manner according to 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, the suggestions you can independently prevent and reduce the risk, and the remedial measures for you, etc. We will timely inform you of the relevant information of the event by email, letter, telephone, push notification and other means. When it is difficult to inform the user information subject one by one, we will take a reasonable and effective way to release announcements.

7.5 We will fulfill the obligations of storing, keeping and using user information in accordance with relevant laws and regulations. At the same time, we will also report the handling of user information security incidents in accordance with the requirements of the regulatory authorities.

7.6 In the event that our products and services cease operation, we will take reasonable measures to protect the security of your user information, including timely stopping the activities of continuing to collect user information; The notice of operation cessation will be notified to users in the form of one-by-one service or announcement; And the personal information held by the deletion or anonymous processing.

8. Protection of Minors' Information

8.1 We do not accept children to register as our users, and we do not accept personal information provided by users under the age of 18. Please note and provide it with caution. If any of our products or services are intended for minors, we ask you to ask your parents or guardians to read this Privacy Policy carefully and to use our services or provide us with information with the consent of your parents or guardians.

8.2 Although the definition of a child varies by law and custom from place to place, we consider anyone under the age of 14 to be a child. If we have collected personal information from children under 14 years of age without our knowledge, we will delete the information in a timely manner unless we are required by law to retain such information.

8.3 We will only use, share, transfer or disclose the personal information of minors that is collected with the consent of parents or guardians to use our products or services when laws and regulations permit, parents or guardians express consent or are necessary to protect minors.

8.3 If we find that personal information of children has been collected without prior verifiable parental consent or by mistake or accident, we will take measures to delete such information as soon as possible.

8.4 If you are the parent or other guardian of a minor and you have any questions about the personal information of the minor under your custody, please contact us through the contact information published in this Privacy Policy.

8.5 For users in the United States, we guarantee compliance with the Children's Online Privacy Protection Act COPPA).

9. Users' Rights

In accordance with the relevant laws, regulations and standards of China, as well as the common practices of other countries and regions, we guarantee that you can exercise the following rights with your personal information:

9.1 You have the right to access your user information by logging into your account on the ITNIO TECH Website, subject to exceptions set forth in laws and regulations. If you cannot access user information normally, you can send an email to us and we will respond to your request for access within 30 days. For other user information arising from your use of our products or services, we will provide you with such information within reasonable technical means and cost.

9.2 Correcting your User Information: If you find that your user information is incorrect and cannot be modified by yourself, you can send an email to us and we will respond to your request for correction within 30 days.

9.3 Each service function requires some basic user information to be completed. You may grant or withdraw your authorized consent at any time for the collection and use of user information beyond the requirements of the business. After you withdraw your consent, we will no longer process the corresponding user information. However, your decision to withdraw your consent will not affect the processing of user information previously conducted based on your authorization.

9.4 We will delete your personal information when the following situations occur.

1) The processing purpose has been realized, cannot be realized, or is no longer necessary to realize the processing purpose;

2) Stop providing products or services, or the storage period has expired;

3) You withdraw your consent to us;

4) Other circumstances provided for by laws and administrative regulations.

If the retention period prescribed by laws and administrative regulations has not expired, or if it is technically difficult to delete personal information, we will stop processing it except storing and taking necessary security protection measures.

When personal information is deleted, we will adopt commercially reasonable standardized measures to make personal infringement virtually impossible to recover or reproduce. The exact type of deletion depends on the information being removed, how it is collected and stored, and how you interact with us. Electronic files containing personal information will be deleted by technical means so that such information is virtually impossible to recover or retrieve, or so that the data can no longer identify the individual. Non-electronic documents containing personal information will be shredded or destroyed.

9.5 If you are a resident of the European Union, you may exercise your privacy rights in accordance with the General Data Protection Regulation GDPR). These rights are not absolute and in some cases we may deny your request to the extent permitted by law. We will need to verify your identity to process your information, access and removal requests and reserve the right to confirm your residence in the EU. We ask users to pay special attention to: When processing personal information, users should comply with GDPR if they meet any of the following conditions:

1) The user is in the economic area of the European Union " EEA "), whether or not the processing activity is carried out in the European Union;

2) To provide goods or services whether paid or not) to individuals in the EEA, or to monitor their conduct in the EEA;

3) Outside the EEA but applicable to the laws of EU Member States in accordance with public international law e.g. embassies or consulates of EEA member States).

9.6 If you are a resident of the State of California, you may exercise your privacy rights pursuant to the California Consumer Privacy Act CCPA). We do not sell or share consumer personal information, and we do not discriminate against consumers for exercising their rights. These rights are not absolute and in some cases we may deny your request to the extent permitted by law. We will need to verify your identity to process your information, access and removal requests, and reserve the right to confirm your residence in California.

9.7 In order to respond to your request and confirm your identity, you may be required to provide a written request or otherwise prove your identity . We may ask you to verify your identity first. We will give you a reply within 30 days. For your reasonable request, we do not charge fees in principle, but for repeated requests, beyond the reasonable limit, we will charge a certain cost according to the situation. We may reject requests that are unnecessarily repetitive, require too much technology for example, the development of new systems or fundamental changes to existing practices), pose a risk to the legitimate interests of others, or are highly impractical.

10. Legal statement and update of privacy policy

10.1 In accordance with the Network Security Law of the People's Republic of China, the Data Security Law of the People's Republic of China, the Personal Information Protection Law of the People's Republic of China and the laws and regulations of the Internet industry, And refer to "Information Security Technology Personal Information Security Code" GB/T 35273-2020) and other recommended national standards to protect users' personal information.

10.2 We may amend the terms of the Legal Statement and Privacy Policy as appropriate and such amendments form part of this Privacy Policy. If there is a change in any important rule that may materially reduce your rights under this Privacy Policy or expand the scope of the information we collect or use, we will notify you of the amendment by placing it prominently on the ITNIO TECH website or by sending you an email or otherwise before it becomes effective. In such circumstances, by continuing to use our services, you agree to be bound by this Privacy Policy as amended.

10.3 All website content, design, text, graphics, images, logos, buttons, ICONS, interfaces, audio and video, and any combination thereof are the exclusive property of us or their respective content providers and are protected by Chinese and international copyright laws.

10.4 Laws of the People's Republic of China shall apply to the establishment, effectiveness, performance, interpretation and dispute resolution of this Privacy Policy. In case of any dispute or dispute between users and us, first of all, it shall be settled through friendly negotiation.. If no agreement can be reached through negotiation, the User agrees to submit the dispute or dispute to the court of competent jurisdiction in Hong Kong.

10.5 This Privacy Policy does not apply to the products or services of external parties or third parties. Users' use of external parties or third parties will be bound by the service terms and privacy policies of these third parties but not this Privacy policy). For specific provisions, please read the terms and conditions of the third parties carefully. Please protect your information properly and provide it to third parties only when necessary.

11. Other agreements

11.1 The owner of the Website refers to ITNIO TECH LIMITED, which is the business entity authorized or registered by the government according to law.

11.2 If you have any questions or comments about the contents of this Privacy Policy or the practices of ITNIO TECH, you can contact us by sending an email to privacy@itniotech.com. We will review the issue as soon as possible and respond within 30 days after verifying your user identity.

11.3 Our contact addresss: Room 803,QiShi Building, 45-51 Chatham Road South, Tsim Sha Tsui, Kowloon, Hong Kong, ITNIO TECH Legal Affairs. Please ensure that you include proof of identity if you are consulting on behalf of the company, please include the company's business license, power of attorney, etc.), address, email or other contact information and relevant information so that we can respond promptly.

11.4 This Privacy Policy is published in both Chinese and English. In case of any inconsistency between the two languages, the Chinese version shall prevail.

11.5 Effective date of this Privacy Policy: May 31, 2023.

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