Personal Information Protection Policy
Update Date: December 2022
Effective Date: December 2022
Thank you for using the services provided by ECOVOX.
We will provide you with ECOVOX portable Wi Fi products and mobile data connectivity services. When you use the above products and services, we may collect, use, store, and share your relevant personal information. Before providing us with your personal information, please ensure that you have carefully read this Personal Information Protection Policy ("this Policy").
You acknowledge and confirm that by selecting 'Agree' to this policy and using or continuing to use the services we provide, you agree to our collection, use, storage, sharing, and protection of your personal information in accordance with this policy. If you do not agree with the content of this policy, it may result in your inability to continue using all or part of our services. Please exercise caution in your judgment. Please note that we will update this policy in a timely manner, so the content of relevant personal information protection clauses may change accordingly. We will inform you of the updated content through prominent notification methods such as pop ups when there are substantial changes to this policy. By reading and clicking "Agree", you will be deemed to have agreed to the updated personal information protection policy.
This policy applies to the ECOVOX APP and other ECOVOX online platforms that we operate and manage.
The terms "ECOVOX" and "we" mentioned in this policy refer to ECOVOX, and "you" refers to the users protected by this policy. We attach great importance to protecting your personal information and privacy security. We understand that your use of our services is based on trust in us, and we value this trust. We also understand the importance of privacy to you and make every effort to protect your privacy. If you have any questions or suggestions regarding this policy, please contact us through the contact information provided in Article 8 of this policy.
This policy will help you understand the following:
1、 Personal Information Collection and Use Rules for Various Business Functions
2、 How do we use cookies
3、 How do we share, transfer, and publicly disclose your personal information
4、 How do we protect and preserve your personal information
5、 Your rights
6、 How do we handle children's personal information
7、 How to update this policy
8、 How to contact us
Personal information refers to various information related to identified or identifiable natural persons recorded electronically or in other ways.
Personal sensitive information refers to personal information that, once leaked or illegally used, can easily lead to the infringement of a natural person's personal dignity or endanger their personal and property safety, including biometric, religious beliefs, specific identities, medical and health information, financial accounts, whereabouts, and personal information of minors under the age of fourteen. We will prominently mark specific sensitive personal information in bold in this policy. Please pay close attention to this.
Our products and services include basic business functions and extended business functions.
Basic business functions: Our products and services include some basic business functions, which include registering an account, viewing, purchasing, and using our products and services to achieve the necessary functions for mobile data connection business.
Extended business functions: Other functions beyond the basic business functions provided by our products and services belong to extended business functions.
We will provide a detailed introduction on how to collect, use, share, transfer, and publicly disclose your personal information based on business functions, so that you can better understand the relevant situation.
(1) Register an account
When you register as our user, we will collect your phone number, email, Google account, or Apple virtual login account, or one of the four login information provided with your consent. If you register using your phone number or email, we will also collect your login password.
We will collect your selected and submitted permanent residence, and you can enjoy exclusive discounts for that location and its surrounding areas.
If you do not provide the above information, you will not be able to complete the account registration. But you can use guest mode to browse ECOVOX portable WiFi device and data package product information before registration, in order to decide whether to further use our products and services.
(2) Improve identity information
You can also set your nickname and fill in your name. If you do not provide the above information, it will not affect your use of our services.
We may contact you through the email address you provided during registration to notify or remind you that your package has expired or to send you promotional information. If you do not wish to receive our notification messages, you can unsubscribe through the unsubscribe method provided in our email.
You can scan the device QR code to bind the ECOVOX portable WiFi device after enabling the camera/camcorder permission. We will only invoke this permission with your consent when you scan the device QR code. If you refuse us to obtain camera/camcorder permissions, you will not be able to bind the device by scanning the QR code. However, you can still select the device type and manually enter the device SN number and initial PWD number to bind the device.
When you purchase a data package, we collect your order information and transaction status, including purchase content, order ID, order amount, order creation time, payment time, payment method, and cancellation time. We need to share your order number, transaction amount information, and other necessary legal requirements with third-party payment institutions to ensure they confirm your payment instructions and complete the payment. To complete the order payment settlement, third-party payment institutions will collect your bank card information and order information in accordance with the law. For the entrusted processing, sharing, transfer, and public disclosure of your personal information, please refer to Article 3 of this policy for details.
If you need us to issue an invoice, you will need to provide us with the necessary information for issuing an invoice separately. Specifically, if you need to issue an invoice with a personal or non corporate name, you need to provide us with the name of the recipient and the email address for receiving the invoice, otherwise we will not be able to issue an invoice for you. If you need to issue an invoice under the company name, you need to provide us with the company name, email address for receiving the invoice, and company tax number, otherwise we will not be able to issue an invoice to you. In addition to the above information, you can also provide us with the company's bank account, company bank account number, company phone number, company address, and remarks information so that we can more conveniently issue invoices for you. If you do not provide these information, it will not affect the issuance of invoices.
During your use of mobile data connection services, we will collect and track your daily data usage for billing purposes based on the data you use.
You can use the guest mode to browse ECOVOX portable WiFi device and data package information through our app, website, and other online platforms without registering or logging in.
In order to provide you with recharge services so that you can purchase data package products more conveniently and at a discounted price, we will collect your account balance information. You can also choose not to use the recharge service and use our mobile data connection service by directly purchasing data packages.
When you use the blacklist function, to avoid your device being mistakenly added to the blacklist and unable to connect to WiFi, we will collect your mobile device MAC address.
Cookies and similar technologies (such as pixels and advertising tags) (collectively referred to as "Cookies") are small data files that, when placed on your device, help us collect data, including your personal information, so that we can perform certain functions and provide specific services. We and our service providers use cookies to collect data and identify you and your device. We do this to better understand the effectiveness of our services and enhance your user experience.
You can modify the settings of your phone according to your needs to refuse cookies. Please note that if you choose to refuse cookies, you may not be able to fully experience the services we provide.
We promise to keep your information strictly confidential. Unless otherwise stipulated by laws, regulations, and regulatory authorities, we only share your information with third parties in the following situations: our affiliated companies, third-party payment institutions, advertising analysis service partners, customer service partners, and other partners. If it is necessary to share your information with a third party in order to provide you with services, we will evaluate the legality, legitimacy, and necessity of the information collected by the third party. We will require third parties to take protective measures for your information and strictly comply with relevant laws, regulations, and regulatory requirements. In addition, we will obtain your consent in accordance with the requirements of laws, regulations, and national standards through confirmation agreements, text confirmations in specific scenarios, pop-up prompts, or confirmation that third parties have obtained your consent.
(1) You expressly agree to share: With your explicit consent, we will share your personal information with other parties;
(2) Legal sharing: We may share your personal information in accordance with the obligations stipulated by laws and regulations, as well as the needs of criminal investigation, prosecution, trial, and judgment execution, as required by administrative and judicial authorities in accordance with the law;
(3) To safeguard our legitimate rights and interests, major public interests, and national defense security sharing: to safeguard our legitimate rights and interests, the lives, property safety, and other legitimate rights and interests of users, other members of society, public safety, public health, major public interests, and national defense security sharing;
(4) Sharing with our affiliates: We may share necessary personal information with our affiliates, and our affiliates will take protective measures no less stringent than this policy and equally strict;
For companies and organizations with whom we share personal information, we will sign strict confidentiality agreements requiring them to handle personal information in accordance with this policy and other relevant confidentiality and security measures. Our partners have no right to use the shared personal information for purposes unrelated to the purposes stated in this policy; If we want to change the purpose of processing personal information, we will seek your authorization and consent again.
We will not transfer your personal information to any company, organization, or individual without your consent, except in the following circumstances:
(1) Obtaining your explicit consent or authorization in advance;
(2) When it comes to mergers, acquisitions, or bankruptcy liquidation, if there is a transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this personal information protection policy. Otherwise, we will require the company or organization to seek your authorization and consent again; If sensitive personal information is involved, your explicit consent will be obtained in advance.
Without your consent, we will only publicly disclose your personal information in the following situations:
(1) According to your needs, disclose the personal information you have specified in the disclosure method that you have explicitly agreed to;
(2) In accordance with the requirements of laws, regulations, mandatory administrative law enforcement or judicial requirements, we may publicly disclose your personal information based on the required type and disclosure method. Subject to compliance with laws and regulations, when we receive a request for disclosure of the aforementioned information, we will require the other party to provide corresponding legal documents, such as subpoenas or investigation letters;
(3) To safeguard our legitimate rights and interests, the lives, property safety, and other legitimate rights and interests of users, other members of society, public safety, public health, major public interests, and national defense security, we do not need to obtain your authorization or consent for public disclosure.
We attach great importance to information security and have established a dedicated team responsible for it. We strive to provide you with information protection and have adopted appropriate management, technical, and physical security measures. We have established an information security protection system that is compatible with business development by referring to domestic and international information security standards and best practices.
We have established security measures at various stages of data collection, storage, display, processing, use, deletion, and destruction from the perspective of the lifecycle of data. Different control measures are taken according to the level of information sensitivity, including but not limited to access control, SSL encrypted transmission or encryption algorithms with AES 256 bit or higher strength for encrypted storage, and sensitive information desensitization display.
We have implemented strict management for employees who may have access to your information, and can monitor their operations. We have established approval mechanisms for important operations such as data access, internal and external transmission and use, anonymization, decryption, etc., and have signed confidentiality agreements with the aforementioned employees. At the same time, we also regularly provide information security training to our employees, requiring them to develop good operating habits in their daily work and enhance their awareness of data protection.
We will take all reasonable and feasible measures to ensure that unrelated personal information is not collected. We will only retain your personal information for the period necessary to achieve the purposes stated in this statement, unless an extension of the retention period is required or permitted by law.
Please be aware that there is no security system or system transmitting information through the Internet that can guarantee absolute security. We will do our best to ensure the security of any information you send to us. If our physical, technical, or management protective facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, and causing damage to your legitimate rights and interests, we will bear corresponding legal responsibilities.
After the unfortunate occurrence of a personal information security incident, we will promptly inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you in accordance with the requirements of laws and regulations. We will promptly inform you of the relevant situation of the event through email, letter, phone, push notifications, etc. When it is difficult to inform individual information subjects one by one, we will adopt reasonable and effective methods to publish announcements. At the same time, we will proactively report the handling of personal information security incidents in accordance with regulatory requirements.
In principle, we will only store your personal information within the time limit required to implement your authorized services, unless there is a mandatory retention requirement by law, such as the Electronic Commerce Law of the People's Republic of China requiring the retention of product and service information and transaction information for no less than three years from the date of completion of the transaction. We mainly refer to the following standards to determine the storage period of personal information, and the longer one shall prevail:
After providing services to you, if we continue to keep your transaction records in accordance with the law in order to fulfill our legal obligations, we will not use the information for purposes other than lawful retention. For information that cannot be obligated to be retained, we will promptly anonymize or delete the information after the service purpose is achieved.
If we cease to operate ECOVOX products or services, we will promptly cease the collection of your personal information and notify you of the cessation of operations in the form of individual delivery or announcement, and delete or anonymize the personal information we hold.
According to relevant laws, regulations, standards in China, as well as common practices in other countries and regions, during your use of our products or services, you may access, copy, correct, supplement, or delete your personal information, request us to explain our rules for processing your personal information, exercise the right to change the scope of authorization and consent, refuse personalized product, service display or marketing information, and cancel your account. Within the scope stipulated by laws and regulations, you may request that your personal information be transferred to a designated personal information processor. Additionally, you can contact us through the methods specified in Article 8 of this policy, and your feedback will be promptly addressed.
Account information - You can access your nickname, name, account, and email account through the ECOVOX app under "My" ->"User Profile".
Traffic package information - You can access your traffic package information through the ECOVOX APP 【 My → Traffic Package 】.
Order Information - You can access your order information through the ECOVOX APP 【 My → Order Management 】.
Balance information - You can access your balance through the ECOVOX app 【 My → Balance 】.
Device Information - You can access the device you have bound through the ECOVOX APP [Device].
For other personal information that you cannot access through the above methods, you can contact us through the contact information specified in Article 8 of this policy.
You have the right to correct your personal information. To facilitate the correction of your personal information, we provide two methods for you: online self correction and submitting a correction request to us.
For some of your personal information, you can correct it yourself through the channels in "Accessing Your Personal Information".
You can also seek help from us through the contact information provided in Article 8 of this policy to assist you in correcting your personal information.
In the following situations, you can request the deletion of personal information to us through the contact information specified in Article 8 of this policy:
(1) If our collection and use of personal information violates the provisions of laws and regulations;
(2) If we collect and use your personal information without your consent;
(3) If our collection and use of personal information violates our agreement with you;
(4) If you no longer use our products or services, or if you cancel your account;
(5) If we no longer provide you with products or services.
If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us, requesting them to delete your personal information in a timely manner, unless otherwise provided by laws and regulations, or these entities have obtained your independent authorization.
You can change the scope of your consent or withdraw your authorization by adding, deleting information, changing privacy settings, or enabling/disabling the corresponding functions of your device, as well as contacting us through the methods specified in Article 8 of this policy.
However, please note that various products or services often require the collection of necessary personal information in order to be implemented. Please understand that when you withdraw your consent, we will no longer be able to provide you with the products or services corresponding to the withdrawal of consent, but it will not affect the personal information processing services previously conducted based on your authorization.
You can cancel your account at any time through the ECOVOX App under "Me" ->"Settings" ->"Account Management" ->"Cancel Account". Your account cancellation will be deemed as your voluntary abandonment of your account balance and unused data package products.
Please note that your account cancellation is an irreversible act. After you cancel your account, we will cease to provide you with products or services, collect your personal information, and delete or anonymize any personal information related to your account after a 60 day cooling off period. Except for the following situations:
(1) There are other provisions in laws and regulations;
(2) According to the requirements of administrative, judicial, and other competent authorities, your account cannot be cancelled;
If permitted by law, you may copy your personal information and request that your personal information be transferred to a designated personal information processor. You can also request us to explain the processing rules for your personal information. You can exercise the above rights by contacting us through the methods specified in Article 8 of this policy.
To ensure safety, you may need to provide a written request or prove your identity in other ways. We may first require you to verify your identity before processing your request.
We will provide a response within fifteen working days. If you are not satisfied, you can also file an appeal through the contact information provided in Article 8 of this policy.
For your reasonable requests, we generally do not charge any fees, but for requests that are repeated multiple times or exceed reasonable limits, we will charge a certain cost fee depending on the situation. We may refuse requests that are unnecessarily repetitive, require excessive technical means (such as developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are highly impractical (such as involving information stored on backup tapes).
In the following situations, as required by laws and regulations, we will not be able to respond to your request:
(1) Related to our obligations under laws and regulations;
(2) Directly related to national security and defense security;
(3) Directly related to public safety, public health, and major public interests;
(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments;
(5) There is sufficient evidence to suggest that you have subjective malice or abuse of power;
(6) For the purpose of safeguarding the significant legitimate rights and interests of personal information subjects or other individuals, such as life and property, but it is difficult to obtain their consent;
(7) Responding to your request will result in serious harm to your or other individuals' or organizations' legitimate rights and interests;
(8) Involving trade secrets.
We attach great importance to the protection of children's personal information. We do not intentionally collect personal information from children, and no part of our products and services is intended for children. If you are a child under the age of 14, please do not use or access our products and services in any way. When we become aware that we have unintentionally collected personal information from children, we will delete it or take other appropriate measures in accordance with applicable laws and regulations.
Please understand that we may revise this policy as necessary. We will indicate the date of the latest update to this policy, which will take effect upon publication.
Without your explicit consent, we will not reduce the rights you are entitled to under this policy. For significant changes, we will also provide more prominent notifications (such as pop ups to inform you of the updated content). We suggest that you frequently revisit this policy to read the latest version.
If you have any questions about this policy or personal information protection, please contact us through the following methods:
Normally, we will reply within 15 working days. If you are not satisfied with our response, especially if our personal information processing behavior has harmed your legitimate rights and interests, you can also file a lawsuit with a court with jurisdiction. We hope that you can have friendly negotiations with us before filing a lawsuit with the court. We welcome and thank you for your supervision and suggestions.