PRIVACY NOTICE
Last updated [19/08/2023]
This privacy notice for [NINGBO KINGDUN ELECTRONIC INDUSTRY CO.,LTD] (doing business as[KingDun]) ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
■ Download and use our application(s), such as our mobile application —[KingDun] Questions or concerns? Reading this privacy notice will help you understand your privacy rights andchoices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [app@kingdun.net.cn].
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about anyof these topics by clicking the link following each key point or by using our table of contents belowtofind the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we mayprocess personal information depending on how you interact with [KingDun] and the Services, the choices you make, and the products and features you use. Learn more about personal information youdisclose to us.
Do we process any sensitive personal information? [We do not process sensitive personal information.]
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply withlaw. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information
In what situations and with which types of parties do we share personal information? We mayshareinformation in specific situations and with specific categories of third parties. Learn more about whenandwith whom we share your personal information.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over theinternet or information storage technology can be guaranteed to be 100% secure, so we cannot promiseor guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about howwe keepyour information safe.
What are your rights? Depending on where you are located geographically, the applicable privacylawmay mean you have certain rights regarding your personal information. Learn more about your privacyrights.
How do I exercise my rights? The easiest way to exercise your rights is by filling out our data subject access request form available here: [https://www.kingdun.com/contact/], or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what [KingDun] does with any information we collect? Redivthe privacynotice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REdiv, UPDATE, OR DELETE THE DATA
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us.In Short: We collect personal information that you provide to us
We collect personal information that you voluntarily provide to us when you [register on the KingDun,] express an interest in obtaining information about us or our products and Services, when you participatein activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and featuresyou use. The personal information we collect may include the following:[email addresses][passwords].Sensitive Information. [We do not process sensitive information. ][Application Data. If you use our application(s), we also may collect the following information if youchoose to provide us with access or permission:
■ Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
■ Mobile Device Access. We may request access or permission to certain features fromyour mobiledevice, including your mobile device's camera, album, and other features. If you wish to changeour access or permissions, you may do so in your device's settings.
■ Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings. This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.]
All personal information that you provide to us must be true, complete, and accurate, and you must notifyus of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and devicecharacteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, informationabout how and when you use our Services, and other technical information. This information is primarilyneeded to maintain the security and operation of our Services, and for our internal analytics and reportingpurposes.
The information we collect includes:
■ Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performanceinformation our servers automatically collect when you access or use our Services and whichwerecord in log files. Depending on how you interact with us, this log data may include your IPaddress, device information, browser type, and settings and information about your activityintheServices (such as the date/time stamps associated with your usage, pages and files dived, searches, and other actions you take such as which features you use), device event information(such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicatewith you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent
We process your personal information for a variety of reasons, depending on how you interact withour Services, including:
■ To facilitate account creation and authentication and otherwise manage user accounts. Wemay process your information so you can create and log in to your account, as well as keepyour account in working order.
■ To deliver and facilitate delivery of services to the user. We may process your informationtoprovide you with the requested service. ■ To respond to user inquiries/offer support to users. We may process your information torespond to your inquiries and solve any potential issues you might have with the requested service.
■ To send administrative information to you. We may process your information to send youdetails about our products and services, changes to our terms and policies, and other similar information.
■ To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have avalidlegal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply withlaws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the followinglegal bases to process your personal information:
■ Consent. We may process your information if you have given us permission (i.e., consent) touseyour personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
■ Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
■ Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
■ Send users information about on our products and services
■ Analyze how our Services are used so we can improve them to engage and retain users
■ Diagnose problems and/or prevent fraudulent activities
■ Understand how our users use our products and services so we can improve user experience
■ Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidenceinlitigation in which we are involved.
■ Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the dataprocessing we perform. This privacy notice does not apply to the personal information we process as a“data processor” on behalf of our customers. In those situations, the customer that we provide services toand with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your information on their behalf in accordance withyour instructions. If you want to know more about our customers' privacy practices, you should readtheir privacy policies and direct any questions you have to them
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data withthird- party vendors, service providers, contractors, or agents (“third parties”) who performservices for us or on our behalf and require access to such information to do that work. We have contracts in place withour third parties, which are designed to help safeguard your personal information. This means that theycannot do anything with your personal information unless we have instructed them to do it. They will alsonot share your personal information with any organization apart from us. They also commit to protect thedata they hold on our behalf and to retain it for the period we instruct. The categories of third parties wemay share personal information with are as follows:
■ Cloud Computing Services
■ Data Storage Service Providers We also may need to share your personal information in the following situations:
■ Business Transfers. We may share or transfer your information in connection with, or duringnegotiations of, any merger, sale of company assets, financing, or acquisition of all or a portionof our business to another company.
■ Affiliates. We may share your information with our affiliates, in which case we will require thoseaffiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control withus.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not af iliated with, our Services.
The Services, may link to third-party websites, online services, or mobile applications and/or containadvertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to anythirdparties. Any data collected by third parties is not covered by this privacy notice. We are not responsiblefor the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should rediv the policies of such third parties and contact them directly to respond to your questions.
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
We will not use cookies and similar tracking technologies to access or store information
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in [Ireland]. If you are accessing our Services from outside [Ireland], please beaware that your information may be transferred to, stored, and processed by us in our facilities and bythose third parties with whom we may share your personal information (see "WHEN ANDWITHWHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in [Ireland], and other countries.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as thosein your country. However, we will take all necessary measures to protect your personal informationinaccordance with this privacy notice and applicable law.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out inthisprivacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal informationfor longer than [the period of time in which users have an account with us].
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal informationand isolate it from any further processing until deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguardsand efforts to secure your information, no electronic transmission over the Internet or information storagetechnology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperlycollect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. Youshould only access the Services within a secure environment
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent tosuch minor dependent’s use of the Services. If we learn that personal information fromusers less than18years of age has been collected, we will deactivate the account and take reasonable measures to promptlydelete such data from our records. If you become aware of any data we may have collected fromchildrenunder age 18, please contact us at [app@kingdun.net.cn].
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom(UK), andCanada, you have rights that allow you greater access to and control over your personal information. You may rediv, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protectionlaws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right towithdraw your consent at any time. You can withdraw your consent at any time by contacting us byusingthe contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted inreliance on lawful processing grounds other than consent
Account Information
If you would at any time like to rediv or change the information in your account or terminate your account, you can:
■ Log in to your account settings and update your user account.
■ Contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and informationfrom our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. If you have questions or comments about your privacy rights, you may email us at [app@kingdun.net.cn].
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respondtoDNT browser signals or any other mechanism that automatically communicates your choice not to betracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws. We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we makematerial changes to this privacy notice, we may notify you either by prominently posting a notice of suchchanges or by directly sending you a notification. We encourage you to rediv this privacy notice frequently to be informed of how we are protecting your information
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact us, by email at [app@kingdun.net.cn].
15. HOW CAN YOU REdiv, UPDATE, OR DELETE THE DATA WE COLLECTFROMYOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to rediv, update, or delete your personal information, please visit: [https://www.kingdun.com/contact/], by email at [app@kingdun.net.cn].