CNKEYWORDS Privacy Policy
Latest update time: 5/1/2021
Global Tone Communication Technology Co., Ltd., having its registered office at Room 1601, 16/F, No. 20, Shijingshan Road, Shijingshan District, Beijing, (hereinafter referred to as “GTCOM” or “We”), attaches great importance to the protection of users' personal data and privacy.
During your use of GTCOM’s products or services (hereinafter referred to as “GTCOM products”), we may collect and use your personal data, so we have formulated a privacy policy (this “Privacy Policy”) that covers how we collect, store, use, share and protect users' personal data. With this Privacy Policy, we will explain to you the purpose, method and scope of our collection and use of your personal data, your rights to your personal information, and the measures we take to protect the security of your data.
This Privacy Policy applies to the related services of cnkeywords.net (hereinafter referred to as the "CNKEYWORDS"). Unless otherwise specified in this Privacy Policy, this Privacy Policy does not apply to the products and/or services provided to you independently by third parties that are accessed through our products and/or services, such as those products or websites that are shown to you in search results, or other websites that are linked to through our products and/or services. Please note: When you use third-party products and/or services, if you provide your personal data to that third party, the privacy statements or similar policies of the third party shall apply; we are not liable to any improper use or disclosure of information provided by you by the third party.
Please carefully read and fully understand this Privacy Policy and click or tick “agree” to give your consent before using CNKEYWORDS. The bold part of the policy shall be paid special attention. If you/your guardian disagree(s) with any content of this Privacy Policy, should stop using CNKEYWORDS immediately.
This Privacy Policy will help you understand the following content:
I. How Do We Collect Your Personal Data
II. How Do We Use Cookies and Similar Technologies
III. How Do We Use Your Personal Data
IV. How Do We Retain Your Personal Data
V. How Do We Share, Transfer and Publicly Disclose Your Personal Data
VI. How Do We Protect Your Personal Data
VII. Your Rights to Your Personal Data
VIII. How Do We Process Children's Personal Data
IX. Third-Party Service Providers and Their Services
X. How Is Your Personal Data Transferred Globally
XI. How Is This Privacy Policy Updated
XII. Special Notice Based on CCPA
I. How Do We Collect Your Personal Data
Under this Privacy Policy, "personal data" refers to any information relating to an identified or identifiable natural person.
Our purpose of collecting personal data is to improve the operational efficiently and provide you with the best experience. The channels through which we collect personal data include: (1) information you provide to us; and (2) information collected during your use of products or services.
The information we collected depends on the GTCOM products you actually use, the environment in which you interact with us, the choices you make, including your privacy settings, and the products and functions you use. Our products and functions include core business functions and value-added business functions. It is not your obligation to provide us with your personal data upon our request. However, for core business functions, if you choose not to provide your personal data, we may not be able to provide you with relevant products or services, nor respond to or solve your problems you encounter. For non-core business functions, you may choose whether to agree to our collection of information. If you refuse to agree, it may lead to the failure of relevant business functions, but it will not affect your use of our core business functions.
Please understand that the functions and services we provide to you are constantly updated and developed. If a function or service is not included in the following description and your information is collected, we will further explain to you the content, scope and purpose of such information collection through page prompts, interactive processes, site notices, separate agreements and other means, so as to obtain your consent.
1. The information you provided to us
1.1 To create and maintain your service account
When using the CNKEYWORDS, you may choose to register as a user of the CNKEYWORDS at your discretion. You should register a CNKEYWORDS service account for specific functions such as giving likes, favoriting entries, and applying for creation of entries. In order to create your service account, you should provide us with your e-mail address and set your account password. The above information is necessary for us to create a service account for you. If you refuse to provide the above information, we will not be able to register an account for you and you will not be able to use certain functions, but this will not affect your use of the basic functions of the CNKEYWORDS (such as the retrieval, reading, translation and sharing of all information on the website).
1.2 To provide you with feedback function
The CNKEYWORDS provides feedback functions. If you would like to give feedback to us, we may need you to provide your personal data, including your e-mail address and your comments, so that we can contact you in time and respond to you regarding your comments. You may choose to submit feedback to us at your discretion, which will not affect your using of the basic functions of the CNKEYWORDS.
1.3 To provide you with promotional or marketing activities
We may invite you to participate in promotional or marketing activities such as sweepstakes, contests and questionnaires, held by us during your use of the CNKEYWORDS. If you agree to participate in our promotional or marketing activities, you need to provide us with your name, mobile phone number and e-mail address so that we can contact you and present you with gifts. If you refuse to provide the above information, you may not be able to participate in our promotional or marketing activities, but it will not affect your using of the basic functions of the CNKEYWORDS.
1.4 To facilitate your application for entry creation
You may create entries on the CNKEYWORDS. If you choose to use this function, we will collect and review the entries you submit. Please note that: Please be cautious that the content and information you voluntarily provide, upload or publish when using our products and/or services (such as the information you submit when applying for entry creation) may reveal your sensitive personal data. If you disclose your personal data in the information uploaded or posted in a public area visible to other users, or in your response to the information uploaded or posted by other people, such personal data may be collected and used by others. If you find that others have improperly collected or used your personal data, you may contact us through the contact information disclosed in this Privacy Policy.
2. Information collected during your use of products or services
In order to ensure the security of the CNKEYWORDS and user accounts, provide better products and/or services and improve user experience, we may need to collect the information on how you and your device interact with GTCOM products or services during your use of the CNKEYWORDS, including:
(1) Logs and operation history: For example, your use of our products or services, the operation after your account is logged in to (including password modification, modification of the bound mobile phone number, e-mail address, complaint record), search query words entered through the services, software event information (such as restart, upgrade, error and crash), Internet Protocol (IP) address, URL of the service accessed, browser type and language used, downloading, installation or use of mobile applications and software, and the information communicated with the communication software and the date, time, duration and browsing information of accessing the services.
(2) Location information: We may obtain your location information from third parties so that we can understand the language type used by you and your browser. You may turn off the location-based function to stop collection of your geographic location information, but then you may not be able to get relevant services or functions, or you may not achieve the desired effects of relevant services.
3.Information obtained from third parties
Where permitted by law and authorized by you, in order to provide you with better services and meet your individual needs, we may receive your personal data or other data from our affiliates or partners (such as, we may obtain your geographic location information from search engine service providers so that we can understand the language type used by you and your browser). In addition, we may also collect your personal data provided by other parties when using our products or services.
II. How Do We Use Cookies and Similar Technologies
1. What are cookies?
The main functions of cookies mainly include facilitating your use of our website products and/or services, as well as helping us calculate the number of independent visitors. Through use of cookies, we can provide you with more thoughtful personalized services and allow you to set your specific service options.
2. Cookies we use
One of the main purposes of cookies is to provide a practical function that saves time. For example, if you customize the webpages of the CNKEYWORDS, or use multiple services on the CNKEYWORDS, cookies will help you invoke your information during subsequent visits. This can simplify the process of filling in your personal information (such as one-click login). When you return to the homepage of the CNKEYWORDS, the CNKEYWORDS can call up the information you previously provided, enabling you to easily use your customized functions. Technologies such as cookies and web beacons can help you optimize your choice and interaction with advertisements.
When we carry out activities related to products and services on the CNKEYWORDS, we will use network beacons to enter our website to extract cookies.
At the same time, we will also use cookies or similar tracking technologies to analyze trends, manage the website, track user behavior on the website, and collect the overall characteristics of our user base. We automatically collect certain information to analyze cumulative trends and manage our website. This information may include IP address, browser type, Internet service provider (ISP), referring/exit pages, files you view on our website (such as HTML pages and graphics), operating system, date/time stamp and/or clickstream data.
3. Clear/disable cookies
In principle, we will only enable cookies or similar technologies after obtaining your explicit consent, and collect your information through cookies. You may turn on cookie related functions or perform corresponding operations through methods to manage cookies or set cookie preferences in the commonly used browser software disclosed below. We will use cookies and similar technologies strictly in accordance with your wishes.
Certain functions of our products and/or services rely on cookies. If you refuse or delete cookies, you may not be able to log in or use some of our services or functions that are relied on cookie. The following provides you a guide on how to disable, clear or manage cookies in commonly used browser software:
· Microsoft Internet Explorer
· Microsoft Edge
· Mozilla Firefox
· Google Chrome
· Safari for macOS
· Safari for iOS
4. More information about cookies
For more information about our use of cookies and instructions on how to set your browser to accept, delete or disable cookies, please refer to www.allaboutcookies.org. You can also visit our Cookie Policy for more information.
III. How Do We Use Your Personal Data
When we need to fulfill our obligations to you under the user agreement and/or service contract, or our binding legal obligations, or we think it is necessary to protect the legitimate interests of us or any third party through evaluation, we will process your personal data for the purposes described in this Privacy Policy with your consent. We will use your personal data strictly in accordance with this Privacy Policy and updated versions. Your personal data will only be used for purposes for which your explicit consent was obtained at the time of collection. If it is used for other purposes, we will seek your consent in advance.
1. Your personal data will be used in the scenarios specified under "How Do We Collect Your Personal Data”.
2. Your personal data may be used in the following scenarios that are directly or reasonably related to the purpose specified under "How Do We Collect Your Personal Data”:
(1) Providing and improving the products and services: We will use the collected information to provide and improve our products and services, and conduct necessary business operations, such as operating products or providing services, evaluating, maintaining and improving the performance of the products or services, participating in the market surveys concerning our products and services, developing new products or services, and providing customer support.
(2) Statistical analysis on the use of products: In order to improve our products and services, we may also conduct statistics and analysis on the use of products. At the same time, we may share the statistics with the public to display the overall use trend of our services, but the statistics will not contain any information that can identify you.
(3) Information and notification services: We will send you information and notifications, including but not limited to the verification code required to ensure the completion of the services, the push notification required to use the products or services, news coverage about GTCOM and its products or services, and marketing activities and special promotions or other content that may be of interest to you. If you do not wish to continue to receive the above information, you can unsubscribe according to the method provided in the information or notice.
3. We may combine the information collected when you use different GTCOM products to conduct comprehensive statistics and analysis to better meet your individual needs (for example, to enable you to obtain more personalized recommendations). You agree to authorize us and our affiliates, or other partners to share necessary information so that we can provide you with better personalized products or services in general.
4. We may also comprehensively analyze the collected information, determine your account security and transaction risks based on your transaction habits and commonly used software information, conduct identity verification, detect and prevent security incidents, keep necessary records, perform audits and analysis, take treatment measures to better prevent security risks such as publishing websites, fraud, network vulnerabilities, computer viruses, network attacks and network intrusions, and more accurately identify violations of laws, regulations or agreements related to products and services, so as to protect the legitimate rights and interests of you, other users, us or affiliates.
5. We will notify you again and obtain your explicit consent for any use of your personal data beyond the scope of the purpose disclosed in this Privacy Policy.
IV. How Do We Retain Your Personal Data
1. The retention period of personal data we collect is the minimum time required to achieve the collection purposes set forth in this Privacy Policy, unless a longer retention period is required by laws and regulations. If the above retention period expires, we will delete or anonymize your personal data.
2. In the case that we stop operating some or all of our products or services due to special reasons, we will timely notify you and stop the collection and processing of personal data related to products or services, and delete or anonymize the personal data in our possession in connection with such products or services, unless otherwise stipulated by laws and regulations.
V. How Do We Share, Transfer and Publicly Disclose Your Personal Data
1. Currently, we will not actively share or transfer your personal information to any third party other than GTCOM. In the event that it is required to share or transfer your personal information or you require us to share or transfer your personal information to a third party other than GTCOM, we will obtain or confirm that the third party has obtained your authorization and consent to the above actions.
2. In the event of a merger, acquisition or bankruptcy involving a transfer of personal information, we will require the company or organization newly holding your personal information to continue to be bound by the Privacy Policy; otherwise we will require the company or organization to re-request you for authorization and consent. If the transfer of personal information is not involved, we will fully inform you and delete or anonymize all personal information in our possession. Internally, in the previous acquisition and merger activities, the data (including user data) managed by the acquired and merged company or organization will be processed and protected by the same standards and requirements as the data owned by GTCOM.
3.We will abide by relevant laws and regulations and keep your personal information confidential. We will not publicly disclose your personal information except with your express consent or authorization in advance, or as required by law. We may only publicly disclose your personal data as demanded by law, subpoenas or other legal procedures, litigation or mandatory requirements of government authorities, and if we sincerely believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to government requests, we may publicly disclose your personal data.
VI. How Do We Protect Your Personal Data
1. In order to ensure the security of your information, we will take reasonable and necessary measures to protect your information under the current development level of technologies, and adopt physical, technical and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure and change of data, including but not limited to transport layer data encryption, firewall and encrypted storage, physical access control, and information access authorization control. To this end, we have security programs in place to protect your information from unauthorized access. All personal data is encrypted and stored inside professional firewalls.
2. We have established relevant systems, procedures and organizations to ensure the security of your information. For example, we strictly limit the scope of people who can access information and require them to comply with confidentiality obligations.
3. When you use our services, please take good care of your account number and password, as we will identify you by your account number and password. Once your account number and password are known by others, you may lose your information and may have adverse legal consequences against you. If you find that your account and password have been or will be known by others for any reason, you should contact us immediately so that we can take appropriate measures to prevent or reduce the relevant losses.
4. In the event of a security incident such as personal data leakage, we will initiate an emergency plan to prevent the expansion of the security incident, and notify you in the form of push notifications, announcements, etc.
5. The Internet environment is not completely secure, and we will do our best to ensure or guarantee the security of any information you send to us. In the event that our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, thereby causing damage to your legitimate rights and interests, we will bear the corresponding legal liability.
VII. Your Rights to Your Personal Information
We respect your right to your personal information. The following lists your legal rights and explains how we will protect them.
1.Right to know: We inform you of how we deal with your personal information by publishing this Privacy Policy. We are committed to ensuring transparency in the use of your information.
2.Right to access:
You can directly query or access your personal data in our product or service interface, such as, you can log in to your account at any time through the product page to access personal data related to your account, including basic information, operation history, storage and downloads history; you can also browse information about your use of products or services at any time, for example, you can access your browsing history in a browser. If you are unable to inquire or access your personal data on your own, or encounter any problems in the process of exercising your right to access, you can contact us to request access through the contact information disclosed in this Privacy Policy, and we will deal with it and give feedback in a timely manner according to the requirements of laws and regulations.
You can query and access your personal data through: [Logging into CNKEYWORDS - Personal Center]
3.Right of correction:
You have the right to ask us to rectify or supplement your personal data we deal with if you find that it is incorrect or incomplete. For some of your personal data, you can directly rectify or modify it on the relevant function page of the product or service. For personal data that has not yet been provided to you with a channel for self-modification, you can also contact us through the contact information disclosed in this Privacy Policy to request us to rectify or supplement your personal data. We will deal with and send feedback on it in a timely manner in accordance with laws and regulations.
You can correct your personal information by: [Logging into CNKEYWORDS -- Personal Center -- Personal
Profile/Security Settings].
4.Right to erasure/deletion:
You can erasure/delete specific information submitted by you directly from the product interface through your account, such as your mobile phone number. If we collect and use your personal data in violation of our agreement with you, you can also contact us through the contact information disclosed in this Privacy Policy to request us to erasure/delete your personal information. We will deal with and send feedback on it in a timely manner in accordance with laws and regulations.
You can delete your personal information by: [Logging into CNKEYWORDS -- Personal Center -- Personal
Profile/Security Settings].
5.Right to cancel account:
We provide account cancellation service for you. You may cancel your account in the product interface. After you choose to cancel your account, we will delete or anonymize all your personal data in a timely manner in accordance with laws and regulations, unless otherwise provided by laws and regulations. After you log out, we will no longer be able to provide you with products or services that require account login.
We provide account cancellation service for you. You may cancel your account in the product interface. After you choose to cancel your account, we will delete or anonymize all your personal data in a timely manner in accordance with laws and regulations, unless otherwise provided by laws and regulations. After you log out, we will no longer be able to provide you with products or services that require account login.
6.Right to restriction of processing:
processing of your personal data. This means we can store it, but we cannot process it further. We will only retain the data needed to respond to your request in the future. You can contact us through the contact information disclosed in this Privacy Policy and exercise your right to restrict processing. We will deal with it and give feedback in a timely manner in accordance with laws and regulations.
You can realize your right to restrict processing by: [sending an e-mail to the following address: MSGbusiness@gtcom.com.cn].
7.Right to data portability:
To the extent permitted by laws and regulations, you have the right to access your personal data in a structured, common, and machine-readable format. For example, if you decide to change to a new service provider, this right allows you to reliably and securely move, copy or easily transfer your personal data between our IT system and their IT system without affecting its use.
After providing the formal authorization, you can implement your right to data portability by sending an e-mail to the following address: [MSGbusiness@gtcom.com.cn].
8.Right to object:
Even if the processing of your data is for our legitimate interests, the exercise of public power, direct marketing (including data aggregation), and statistical reasons, you also have the right to object the GTCOM to process your personal data.
You can realize your right to object by sending an e-mail to the following address: [MSGbusiness@gtcom.com.cn].
9.Right to withdraw consent:
Certain basic personal data is required for realizing each business function (see the section "How Do We Collect and Use Your Personal Data" of this Privacy Policy). You can change the scope of your consent to continue collecting personal data or withdraw your consent by deleting information, canceling your account, etc.
In addition, you can change your consent by: [logging into the CNKEYWORDS -- Personal Center -- Personal Profile to change your consent by deleting information], or by [logging into the CNKEYWORDS -- Personal Center -- Account Cancellation to submit your request for withdrawal of consent.].
If you do not want to receive the commercial ads we send you, you can cancel it at any time by: [clicking "Contact us" at the bottom of any page on the CNKEYWORDS to submit your request.]
If you withdraw your consent, we will no longer be able to provide you with services corresponding to the withdrawal of your consent. After you withdraw your consent, we will no longer process the corresponding personal data, but your decision to withdraw your consent will not affect the previous personal data processing activities based on your consent.
10.Right to refuse automated decision-making: You have the right not to be subject to decisions made by automated processing, including user portraits. If these decisions significantly affect your legal rights, you can reject the automated decision-making by sending an e-mail to the following address [MSGbusiness@gtcom.com.cn], we will respond to your request and take appropriate measures to resolve it when necessary.
11.Right to complain: You have the right to contact us for complaints through the contact information disclosed in this Privacy Policy, or to file a complaint with the data protection agency of your country about our handling of your personal data.
We will respond to your request and communicate with you in an appropriate way within 30 days from the date of receiving your request. If necessary, we may extend the aforementioned period (up to 30 days) and inform you of the reason for the extension within 30 days from the date of receiving your request. If we have reason to believe that there is no need to take any measures for your request, we will inform you of our decision within 30 days from the date of receiving your request and give you an explanation accordingly. If you are not satisfied with the response you receive, you can also file a complaint or report with the corresponding supervisory authority in your jurisdiction, or file a lawsuit to a court with jurisdiction.
VIII. How Do We Process Children's Personal Data
1. Our website, products and services are not available to children under the age of 16 (or the age stipulated by applicable laws and regulations in your jurisdiction). Children are not allowed to use the CNKEYWORDS without the company of their parents/guardians, nor can they create their own accounts.
2. If we find that we have collected personal data of children without the prior consent of a verifiable guardian, we will try to delete the relevant data as soon as possible.
3. If you are the guardian of a child, when you have any queries about the information processing of the child under your custody, or if you have facts that prove that the child has registered and used our products and/or services without the consent of the guardian, please contact us through the contact information disclosed in this Privacy Policy.
IX. Third-Party Service Providers and Their Services
1. Our websites, products, applications and services may contain links to third-party websites, products and services. You may choose whether to visit or accept the websites, products and services provided by third parties. The "About Us" function on the GTCOM's official website will guide you to visit our official account in the social network platform, where you can learn about the marketing or promotional information released by us.
2. We have no control over the privacy and data protection policies of third parties who are not bound by this Privacy Policy. Please check and understand the privacy policies of these third parties before submitting personal data to third parties.
X. How Is Your Personal Data Transferred Globally
1. As we provide CNKEYWORDS products and services globally, for global business needs, we may transfer your personal data (including the type of information under "How Do We Collect Your Personal Data") to other jurisdictions other than the country where you use this product, or your personal data may be accessed from these jurisdictions.
2. We will store the data (including the type of information under "How Do We Collect Your Personal Data") that you generate and collect when you use CNKEYWORDS products and services in mainland China.
3. When your personal data is transferred to a country located outside the European Economic Area, we will ensure that proper protection measures are in place. For example:
(1) The country or region where the personal data recipient is located benefits from the adequacy decision made by the European Commission according to Article 45 of the General Data Protection Regulations (“GDPR”); or
(2) The personal data recipient has signed the standard data protection contractual clauses approved or adopted by the European Commission according to Article 46 of GDPR.
4. In the absence of the above-mentioned proper protection measures, we will request your explicit consent for the cross-border transfer of personal data, and at the same time implement security measures such as encryption or de-identification to protect the security of your personal data.
5. If you would like to obtain a standard data protection contractual clauses, or learn more about the protection measures related to the transfer of personal data outside the European Economic Area, please contact us via sending an e-mail to [MSGbusiness@gtcom.com.cn].
XI. How Is This Privacy Policy Updated
1. In the event of a major change, our Privacy Policy may be amended. Without your explicit consent, we will not limit the rights you shall enjoy under the Privacy Policy. We will post any amendment to the Privacy Policy on particular pages. If you continue to choose to use our products or services, it means that you have agreed to be bound by the updated Privacy Policy and its relevant policies.
2. In addition, we will provide a more conspicuous notification for major amendments (including, we will give a notice by way of website announcement for some certain services, specifying specific amendments to the Privacy Policy).
3. Major amendments referred in the Privacy Policy include, but are not limited to:
(1) Major changes in our service model. For example, the purpose of processing personal data, the types of personal data handled, and the use of personal data;
(2) Major changes in our control rights, equity structure and organizational structure. For example, change of owners caused by business adjustment, bankruptcy, merger and acquisition, and others;
(3) Changes in the main objects of personal data sharing, transfer or public disclosure;
(4) Significant changes in your rights regarding the processing of personal data and how to exercise them;
(5) Changes in the department in charge of personal data security, contact information, and complaint channels.
This Privacy Policy is effective as of the date of update.
If you have complaints and reports about network information security, or if you have any questions, comments or suggestions about this Privacy Policy, your information, and questions about this statement or the GTCOM’s privacy measures, please contact us through the following contact information, we will timely deal with and feedback according to laws and regulations:
Add.:
E-mail: [MSGbusiness@gtcom.com.cn]
You can also contact our Data Protection Officer (DPO) in the following ways:
E-mail: [security@gtcom.com.cn]
XII. Special Notice Based on CCPA
Please refer to Attachment 1.Attachment 1: Special Notice Based on California Consumer Privacy Act
Attachment 1: Special Notice Based on California Consumer Privacy Act
This special notice serves as a supplement to the CNKEYWORDS Privacy Policy and constitutes an important part of the CNKEYWORDS Privacy Policy. It is applicable to residents of the State of California in the United States (hereinafter referred to as "Californian residents" or "you") who access and use our CNKEYWORDS. We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA"). The last update date of this special notice is [ ] [ ], [ ].
This special notice will explain to you:
1. The categories type of your personal information we have collected in the past 12 months and its sources
2. Our purpose for collecting your personal information
3. How we shared your personal information for business purposes in the past 12 months
4. No sale of personal information
5. Your rights under the CCPA
6. Non-discrimination principle
7. California Shine The Light Law
The "personal information" mentioned in this special notice refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.. Please read this special notice carefully to understand our practices regarding customer personal information and privacy protection before using our products (or services) and submitting personal information.
1. The categories of your personal information we have collected in the past 12 months and its sources
You have the right to know the categories of personal information we collect from you and the specific purpose for which we collect this information. The personal information we collected in the past 12 months and its sources are as follows:
(1) The personal information you provide to us, including:
- Identifiers, such as phone number, e-mail address and IP address;
(2) The personal information we collect when you use the CNKEYWORDS, including:
- Internet or other electronic network activity information: Including your use of our products or services, operation behavior after your account login (including changing the password, the bound mobile phone number and e-mail address, as well as complaint record), search terms entered through the service, software event information (such as restart, upgrade, error and crash), Internet Protocol (IP) address, the URL of the accessed service, the type of browser and the language used, information about downloading, installing, or using mobile apps and software, information communicated with communication software, and the date, time, duration, and browsing information of accessing the service.
- Geolocation data: We may obtain your geolocation data from search engine service providers so that we can understand the language type used by you and your browser. You may turn off the positioning function to stop collection of your geographic location information, but then you may not be able to get relevant services or functions, or you may not achieve the desired effects of relevant services.
(3) We obtain your personal information from third parties
- Where permitted by law and authorized by you, in order to provide you with better services and meet your individual needs, we may receive your personal information or other information from our affiliates or partners (such as, we may obtain your geographic location information from search engine service providers so that we can understand the language type used by you and your browser).
- In addition, we may also collect personal information about you provided by other parties when using our products or services.
2. Our purpose for collecting your personal information
We use your personal information collected mainly for the following purposes:
(1) To create and maintain your service account: We will use the e-mail address you provided and the account password you set to create a service account for you.
(2) To provide you with feedback function: The CNKEYWORDS provides feedback functions. If you would like to provide us with feedback, we will require you to provide and collect your personal information, including your e-mail address and your comments, so that we can contact you in time and respond to you regarding your comments.
(3) To provide you with promotional or marketing activities: We may invite you to participate in promotional or marketing activities such as sweepstakes, contests and questionnaires, held by us during your use of the CNKEYWORDS products. According to your wishes, we will use the name, mobile phone number or e-mail address you provided to us to contact you and present you with gifts.
(4) To facilitate your application for entry creation: You may apply to create entries on the CNKEYWORDS. If you choose to use this function, we will use the content of the entry you submitted for the review of the entry.
(5) In order to provide and improve products and services: We will use the collected information to provide and improve the products and services provided by us and our affiliates, partners and other trusted third-party suppliers, service providers and agents, and perform necessary business operations, such as operating products or providing services, evaluating, maintaining and improving the performance of products or services, participating in market researches about our products and services, developing new products or services, providing customer support, etc.
(6) In order to conduct statistical analysis of product use: In order to improve our products and services, we may also conduct statistics and analysis on the use of products. At the same time, we may share the statistics with the public to display the overall use trend of our services, but the statistics will not include any information that can identify you.
(7) In order to provide information and inform services: We will use the collected information to provide and improve our products and services, and make necessary business operations, such as operating products or providing services, evaluating, maintaining and improving the performance of the products or services, participating in the market surveys concerning our products and services, developing new products or services, and providing customer support.
(8) In order to comprehensively determine account security and transaction risks: We may also comprehensively analyze the collected information, determine your account security and transaction risks based on your transaction habits and commonly used software information, conduct identity verification, detect and prevent security incidents, keep necessary records, perform audits and analysis, take treatment measures to better prevent security risks such as publishing websites, fraud, network vulnerabilities, computer viruses, network attacks and network intrusions, and more accurately identify violations of laws, regulations or agreements related to products and services, so as to protect the legitimate rights and interests of you, other users, us or affiliates.
(9) Respond to law enforcement requests in accordance with applicable laws, court orders or government regulations.
Without your consent, we will not collect other types of personal information other than the scope disclosed in this special notice, nor will we use the personal information we collect for any other purposes not related to the above.
3. How did we share your personal information for business purposes in the past 12 months
You have the right to know whether your personal information is shared with any third party. Currently, we will not actively share or transfer your personal data to any third party other than the GTCOM. In the event that it is required to share or transfer your personal data or you require us to share or transfer your personal data to a third party other than the GTCOM, we will obtain or confirm that the third party has obtained your authorization and consent to the above actions.
4. No sale of personal information
You have the right to know whether your personal information is sold or not. As defined in CCPA, “sell,” “selling,” “sale,” or “sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
We do not sell personal information, so in the past 12 months, we have not sold any of your personal information.
5. Your rights under the CCPA
(1) Your rights
According to the provisions of CCPA, you have the following rights:
- Right to know/access: To understand how we have collected and used your personal information in the past 12 months.
- Right of data portability: To obtain a copy of your personal information.
- Right to request deletion: To delete your personal information.
- Right to opt-out of the sale of personal information: we do not provide opt-out mechanism as we do not sell your personal information.
(2) Channels for rights request
You can exercise your rights request through the following channels. Once we have received and verified your request, we will respond in accordance with the requirements of the CCPA:
- [MSGbusiness@gtcom.com.cn]
(3) Exercise of your rights
Please note that only you or a person registered with the California Secretary of State who is authorized to act on your behalf can make a verifiable request related to your personal information. You may also make a verifiable request on behalf of your minor children.
Please note that according to the CCPA, we are not obliged to respond to requests for access or right to data portability made by the same consumer more than twice within 12 months.
If it is necessary for us or our service provider to retain your information based on the following circumstances, we may refuse your deletion request:
- Completing transactions that may collect personal information, fulfilling the written warranties or product recalls pursuant to federal law, providing goods or services that you require, or that are reasonably expected in our ongoing business relationship with you, or performing the contract between you and us.
- Detecting security incidents and preventing malicious, deceptive, fraudulent or illegal activities; or prosecuting those responsible for the activities.
- Debugging to identify and repair errors that damage existing intended functions.
- Exercising the right to freedom of expression to protect the right of another consumer to exercise that consumer's right to freedom of expression, exercising other right as provided by law.
- To abide by California Electronic Communications Privacy Act in accordance with Chapter 3.6 of Title 12 of Part 2 of the California Penal Code (commencing with Section §1546).
- Engaging in public or peer-reviewed scientific, historical, or statistical research in accordance with all other applicable ethical and privacy laws in the public interest, provided that you have provided informed consent, and deleting the information may result in the inability or serious impairment of the results of such research..
- According to our relationship with you, only internal use is permitted and such internal use is reasonably consistent with your expectations.
- Complying with obligations under the law.
- Using your personal information internally in a legal manner suitable for the environment in which you provide the information.
(4) Responding to your request
Before responding to your request, we may need to verify your identity and the authenticity of the request. A verifiable consumer request should:
- Provide sufficient information to enable us to reasonably verify that you are the person or authorized representative from whom we collect personal information.
- Describe your request in detail so that we can understand, evaluate and respond correctly.
If we are unable to verify your identity or authority to make a request and confirm that the personal information is relevant to you, we will not be able to respond to your request or provide you with personal information.
We will respond to your request within 45 days after receiving your verifiable request. If we need more time (up to 90 days), we will inform you of the reason and extension in writing. If you are our registered user, we will reply in writing to your registered account. If you are not registered, we will provide a written reply by mail or electronic means according to your choice.
The feedback we provide will only cover the 12 months before the receipt of the verifiable request. If we decide to reject your request, the response we provide will explain why we rejected your request. For your request for the right to data portability, we will choose to provide a format of personal information that is easy to use, and should allow you to transfer information from one entity to another without any problems.
We will not charge a fee to process or respond to your request, unless your request is undue, repetitive or obviously unfounded. If we determine that we may charge a fee for responding to your request, we will inform you of the reason for the fee and provide you with an estimate of the fee before responding to your request.
6. Non-discrimination principle
We will not discriminate against you for exercising the rights granted to you by the CCPA. Unless otherwise specified by the CCPA, we will not:
(1) Refuse to provide you with goods or services;
(2) Charge you different prices or fees for goods or services;
(3) Provide you with goods or services of different levels or service quality;
(4) Take other discriminatory measures.
However, if we provide certain financial incentives permitted by the CCPA, these incentives may result in different prices, discounts or quality levels. Any rewards we provide will be reasonably related to the value of your personal information. If we provide these financial incentive plans, you are free to choose whether to participate. If you choose to participate, you will be bound by the relevant applicable terms, and you can opt out at any time.
7. California Shine the Light Law
We will not disclose your personal information to third parties for their direct marketing of products or services to you.