In order to provide services to you or to better provide our services to you, we will acquire your Personal Information by the following ways no matter whether it is the Personal Data prescribed in this Policy or not:
For example, 1) The Personal Information that you submitted to set up and generate a personal account before using SHALLTRY services or products; and 2) The Personal Information that you provide to SHALLTRY to contact you for after-sales support or interaction in forum.
For example, after providing your Personal Data to SHALLTRY, you may want to know how we use and process your Personal Data and whether we disclose your Personal Data to third parties or not, or you may contact us to request deletion of your Personal Data.
For example, 1) we may collect necessary information to activate your after-sales service, software access, and forum interaction when you use SHALLTRY devices; and 2) we may collect logs generated by abnormal operation of the devices and information on users’ habit to optimize product experience during your use of SHALLTRY devices.
As permitted by law, we may collect your Personal Information from third party’s social networking services or pre-installed third-party applications when you use them.
Trustlook SDK provide security service and it will record certain information that included user’s installed application. Because it will analyze the app collection, app static & behavior analysis to give the app risk report.
Apart from the Personal Data mentioned in this Policy, Personal Information collected by SHALLTRY may also include non-identifiable information. Non-identifiable information refers to the Personal Information that could not lead to the identification of an individual, such as the number of visits to a website, APP downloads, and other statistics. SHALLTRY may decide on its own the processing, use, and disclosure of non-identifiable information.
SHALLTRY shall comply with applicable legal requirements when using your Personal Information. Such requirements generally include:
We may use your Personal Information for the following purposes:
Under the relevant applicable laws, SHALLTRY may disclose your Personal Information under the following situations:
In order to provide better services for you, SHALLTRY may transfer your Personal Information to third countries for storing and processing, or your Personal Information may be accessed by other third countries. Privacy laws may vary among these countries, and we will take appropriate measures to process the Personal Information in accordance with the laws where the Personal Information is located.
As the user of the products or services, you are obliged to ensure the completeness and accuracy of the Personal Data you provided and carefully keep your Personal Data safe. We will protect and update your Personal Data on time and try our best to ensure your normal use of the products and services.
In accordance with your rights under relevant applicable law, you may exercise: 1) right of access, i.e. the right to have access to your Personal Data held by SHALLTRY and to know whether Personal Data concerning him or her are being processed or not; 2) right to rectification, i.e. the right to request rectification of the inaccurate Personal Data we hold concerning you; 3) right to erasure, i.e. the right to request us to erasure of the Personal Data concerning you; 4) right to restriction of processing, i.e. the right to restrict our processing of your Personal Data; 5) right to object, i.e. the right to object to our processing of your Personal Data; 6) right to data portability, i.e. the right to request us, where technically feasible, to have your Personal Data transmitted to another data controller. To request exercising your rights under the applicable law, please fill out the form attached to this Policy and send to us via email at firstname.lastname@example.org. We will reply to you in time.
While you are exercising your rights under the applicable law, we may investigate the legality and rationality of your request. If we have reasonable grounds or suspect that your request is deceptive, repetitive or infringes upon the rights and freedom of third parties, or if we are unable to get through the investigation, we may ask you to provide further information or may refuse to process your request. You may send your request in written form in order to protect your legitimate rights and interests. After receiving your request, we will process within the period of time as prescribed by applicable law. If you consider that we are in violation of applicable law and have infringed your legitimate rights, you may file a complaint with the authority for the protection of Personal Data in order to resolve the issue.
We will provide security measures to SHALLTRY users. We will take reasonable and practicable measures to protect your Personal Data that we collected and prevent your Personal Data from being accessed, tampered, disclosed or destroyed by unauthorized third parties. For example, when you access SHALLTRY account, we have user validation procedure or password retrieve procedure to ensure the security of your account.
In the matter of the storage of Personal Data, we have provided security measures to you as well. All your Personal Data will be stored in the secure server, and we will control and protect all the Personal Data. We will determine the storage period of your Personal Data in accordance with the terms and conditions of applicable law. From the perspective of protecting you and your privacy right to the maximum extent, except as otherwise compulsorily stated by law, we will limit the period for which your Personal Data is stored to a strict minimum degree provided that it satisfies the data processing purposes prescribed in this Policy. Our criteria for how long we keep Personal Data mainly include the following two points: 1) time needed to store Personal Data for completing the relevant business; 2) terms and conditions of applicable law. In addition, there are duties of confidentiality in the contract signed between SHALLTRY and its partners. If a partner breaches the confidentiality obligation in the contract and brings about losses to the obligee, SHALLTRY will impose legal liabilities on the partner and terminate the business relationship with the partner.
There is no absolutely safe website, Internet transmission, computer system and wireless connections. Except the necessary protective measures we have taken, users have to strengthen the awareness of privacy security risks. For example, when skipping to third party websites, links, products or services through our services, please carefully read through the terms and conditions or privacy policies of such websites, links, products or services regarding the security of the data and information collected by them. SHALLTRY shall not be liable for any actions you make thereof. If you find certain contents, advertisements, or functions in our website, products or services that may be possibly provided by third parties, and may possibly endanger your privacy and security, please contact SHALLTRY at email@example.com and we will handle with priority.
Minors are not allowed to use SHALLTRY products and services without the consent and guidance of his or her legal guardians. In principle, we will not take initiative to collect the Personal Data of a minor and only with the consent of his or her legal guardians, we will collect his or her Personal Data. As to the disclosure of the Personal Data of a minor, we will provide, in principle, only when permission is given by his/her legal guardian, or where the law or relevant government sector legitimately requires. In addition, if you find that a minor sends his or her Personal Data to SHALLTRY without the consent of his or her guardian, please fill out the form attached to this Policy and send to us via email at firstname.lastname@example.org. We will reply to you in time.
This Policy mainly lays out how SHALLTRY will collect, process and internationally transmit your Personal Information when you browse SHALLTRY website and use SHALLTRY products or services. However, it is impossible to complete enumeration how We collect data, what kind of data We collect, how We use and process the data and the conditions We disclose the data in this Policy. SHALLTRY may send the complementary notice when we collect, process, disclose and internationally transmit your specific Personal Information.
SHALLTRY reserves the right to modify this Policy. If this Policy is modified, SHALLTRY will publish the latest policy in SHALLTRY official website as below:
SHALLTRY has appointed a Data Protection Officer. For any questions in relation to the protection of personal privacy, please contact our Data Protection Officer by filling out the form attached to this Policy and sending the completed form to our email adress at email@example.com. If you have any questions or suggestions about this Policy, please contact us by the following information:
Address: No.1 Building, No.36 Xuelin Road, China (Shanghai) Pilot Free Trade Zone
Feedback Form for Personal Data and Privacy Questions.docx