Key Mall User Privacy Policy

Last Updated Aug 9, 2024

Effective Date: January 09,2024

Shanghai Mingqian Waste Material Recycling Co., Ltd. fully recognizes the importance of personal information to you. In compliance with legal requirements, we implement appropriate security measures to ensure the protection and control of your personal data. To this end, we have established the "Key Mall User Privacy Policy" (hereinafter referred to as "this Privacy Policy" or "this Policy"). Please carefully review all content of this policy, particularly sections highlighted in bold, italicized, or underlined text. You may request explanations for any part or the entire policy by sending an email to songzhimin@mingqianhu.ntesmail.com or contacting our Personal Information Protection Officer or Customer Service.

This Policy applies to all products or services provided by us and our affiliates that have not established separate privacy policies. It does not apply to services provided by other third parties to you, nor to products or services for which separate privacy policies have been set up separately.

Before using any of our services, products, or submitting personal information or privacy details to us, please read, understand, and agree to this Privacy Policy and any supplementary policies in full. Only proceed with using related products or services after confirming your full understanding and consent. If you disagree with any provisions of this Privacy Policy, you should immediately cease using our services. By accessing our products or services, you hereby confirm that you have thoroughly understood and agreed to these terms.

This Privacy Policy will help you understand:

lWe will collect and use your information in accordance with this Privacy Policy, but we will not collect personal information in a mandatory bundle solely because you agree to this Privacy Policy.

lWhen you use or activate relevant features or services, we collect and utilize necessary information to enable these functions. Unless required for essential business operations or legal compliance, you may refuse to provide such information without affecting other services. We will specify in detail the categories of required information in our Privacy Policy.

lIf you are not logged in, we will use the identifier information of the device to ensure the basic function of information push. If you are logged in, we will push information based on the account information.

lPrecise geolocation, camera access, reading of device status and identity (phone permissions, device permissions), and photo album permissions are not enabled by default. These permissions will only be activated when explicitly authorized by you to enable specific functions or services, and you may revoke them at any time. Its important to note that even if we obtain these sensitive permissions through your authorization, we wont collect your information when such functions or services are not needed.

lThis Privacy Policy applies to your access and use of our products and services through this application, the official website, the software Development Kit (SDK) and application Programming Interface (API) used by third-party websites and applications.

1. How we collect and use your personal information

1.1 Information you need to authorize us to collect and use

1) Account Information. To use our services, you need to register and log in to an account. You will be required to provide us with information including but not limited to: mobile phone number, SMS verification code, profile picture (if applicable), etc. After providing this information and agreeing to these terms, you can access core functionalities of the app, such as browsing all content within the app.

2) Additional Information. When you use the supplementary business features of this application, we may require you to provide additional information beyond your account details to fulfill the purpose of offering products and services. This includes but is not limited to your personal mobile phone number, photo album information, and other essential details required for product/service provision. If you do not use these supplementary features or specific products/services, you are not required to provide such information (as detailed below).

1.2 Information you voluntarily choose to authorize us to provide

1) Camera

Purpose of Use: With your authorization, we will collect your camera information to provide you with scanning, taking photos and other functions. You can choose to enable or disable camera authorization. If you disable it, you may not be able to use scanning, taking photos and other functions, but it will not affect your normal use of other services in the APP.

Information: We only collect information when you use the corresponding functions, such as when you use the function of scanning the code to take a photo. The name displayed may vary from system to system, such as camera, camera, etc.

2) Photo albums

Purpose of Use: With your authorization, we will collect your photo album information to provide functions such as photo uploading. You can choose to enable or disable album authorization. If you disable it, you may be unable to use photo uploading and other features, but it will not affect your normal use of other services in the APP.

Information: We only collect information when you use the corresponding function, such as when you upload and save photos. The names displayed may vary from system to system, such as album, storage permission, etc.

3) Device information

Purpose: During your visit or use of our services, we will collect your device information, such as screen resolution, for interface display, to avoid abnormal login of other devices, and to retain necessary log information, so as to ensure the security of your account, transaction and system operation.

Information Disclosure: The device status we collect includes your device model, identifiers such as IMEI/Android ID/IDFA/OPEN UDID/GUID/OAID, SIM card IMSI, ICCID information, Mac address, mobile app list, and telecom operator details. We will not obtain this information without your authorization. Most smartphone manufacturers now support modifying device identifiers to empower users control over personal data. For specific methods of revocation or modification, please refer to the devices user manual.

Please note that standalone device information, log data, and similar information cannot be used to identify specific individuals. However, when such non-personal information is combined with other data for personal identification purposes, or integrated with personal information during this process, it will be classified as personal information.

1.3 Provide you with security guarantee

To ensure account security and system stability while complying with legal requirements and our service agreements, we collect your device information through authorized access during product/service usage. This includes device attributes, connectivity status, and identifiers such as IMEI/Android ID/IDFA/OPENUDID/GUID/OAID, SIM card IMSI, ICCID, Mac addresses, software lists, and telecom operator details.

1.4 Exceptions to authorization and consent

In accordance with relevant laws and regulations, the collection of your personal information does not require your authorization and consent under the following circumstances:

(1) Those involving national security, defense security, public security, state interests or social and public interests;

(2) Those related to criminal investigation, prosecution, trial and execution;

(3) In order to safeguard the life and property safety of you or others, but you cannot obtain your timely authorization under special circumstances;

(4) Collect your personal information from other legal and open channels;

(5) The personal information collected is disclosed to the public by you;

(6) Necessary for the execution of the contract as required by you;

(7) Necessary to maintain the safe and stable operation of the products or services provided, such as discovering and handling faults of products or services;

(8) Other circumstances stipulated by laws and regulations.

2. How we will use your personal information

We will use your personal information for the following purposes:

1) Help your company administrator to complete the account registration for you.

2) Providing you with products or services

3) When we provide services, it is used for identity authentication, customer service, security prevention, fraud monitoring, archiving and backup purposes to ensure the security of the products and services we provide to you.

4) Conduct internal audit, data analysis and research to better improve our products, services and communication with users.

3. How will we use Cookies?

3.1 Cookie

When you use our services, we store small data files called Cookies on your computer or mobile device. These Cookies typically contain identifiers, site names, and specific numbers and characters. We use this information to determine whether registered users are logged in, improve service quality, and enhance user experience. If you do not want your personal information stored in Cookies, you can configure your browser to disable the Cookie function. Disabling the Cookie function may affect your ability to access our website or fully utilize the services we provide.

We will not use Cookie for any purpose other than those described in this policy. You may manage or delete Cookie according to your preference. You may remove all Cookie saved on your computer, and most web browsers have a function to block Cookie.

3.2 Device permission invocation

When providing our services, we may require you to grant access permissions for devices such as notifications, photo albums, camera, and Bluetooth. You can also disable specific or all permissions in your devices settings at any time to prevent us from collecting corresponding personal information. The display and disabling methods of permissions may vary across different devices. For detailed instructions, please refer to the device and system developers documentation or guidelines.

Instructions for iOS operating system permission invocation

Android operating system application permission list

4. How we will share, transfer and publicly disclose your personal information

4.1 Sharing

We will not provide your personal information to third parties without your consent or authorization. However, we may share your personal information with third parties in the following circumstances.

No third-party SDK is connected to this App.

1) Sharing with your explicit consent: With your explicit consent, we will share your personal information with other parties.

2) Sharing with our affiliates: Within the purposes stated in this policy, your personal information may be shared with our affiliates. As a policy, we only share necessary personal information. If an affiliate intends to change the purpose of processing personal information, they will seek your authorization and consent again.

3) Sharing with Authorized Partners: To achieve the purposes of this Policy Statement, some of our services will be provided by authorized partners. We may share some of your personal information with partners to provide better customer service and user experience.

4) Sharing with other users: In order to provide better user services and experience, we may share some of your personal information with other users.

5) Sharing under legal circumstances: We may share your personal information with external parties in accordance with legal regulations, judicial procedures or requirements of administrative or judicial authorities.

6) App PayPal Client SDK Purpose of Personal Information Collection / Third-party SDK Name: App, Alipay Client SDK • Third-party Name: Alipay (China) Network Technology Co., Ltd. • Personal Information Types Collected: Android ID, OAID, SSID, BSSID; system settings, system attributes, device model, device brand, operating system; IP address, network type, carrier information, Wi-Fi status, Wi-Fi parameters, Wi-Fi list. • Usage Purposes: a. Ensure user account security and stable payment service operation. b. Fulfill legal obligations including anti-money laundering, anti-terrorist financing, and anti-telecom network fraud. c. Optimize network path selection to enhance user experience. SDK Privacy Statement Link: App PayPal Client SDK Privacy Statement

7) Other scenarios: When sharing de-identified information where the receiving third party cannot re-identify the information subject; sharing based on reasonable commercial practices; using for academic research purposes; in certain cases, only by sharing your personal information can we achieve core functionalities of our products/services, provide required services, or resolve disputes; sharing with third parties to protect you, other users/employees, our organization, public interests, property, or security (e.g., fraud or credit risk).

4.2 Transfer

We will not transfer your personal information to any company, organization or individual except under the following circumstances:

1) Transfer with explicit consent: We will transfer your personal information to other parties with your explicit consent;

2) In the case of merger, acquisition, reorganization, division, bankruptcy, asset transfer or similar transactions involving us, if the transfer of personal information is involved, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy, otherwise we will require the company or organization to seek authorization and consent from you again;

3) Other circumstances stipulated by laws and regulations.

4.3 Public disclosure

We will only publicly disclose your personal information if and when we take security measures that comply with legal and industry standards

1) Obtain your express consent;

2) Disclosure based on laws and regulations, legal procedures or mandatory requirements of government authorities. However, we guarantee that, subject to the requirements of laws and regulations, when we receive a request for disclosure of the above information, we will require the requesting party to provide corresponding legal documents.

4.4 Exceptions to obtaining prior authorization and consent when sharing, transferring or publicly disclosing personal information

Under the following circumstances, sharing, transferring and publicly disclosing personal information does not require your prior authorization and consent:

(1) those directly related to national security and defense security;

(2) those directly related to public security, public health or major public interests;

(3) those directly related to criminal investigation, prosecution, trial and execution of judgment;

(4) To safeguard the life, property and other major legitimate rights and interests of the subject of personal information or other individuals, but the consent cannot be obtained in time;

(5) Personal information disclosed by you to the public;

(6) Collect personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels;

(7) Necessary for the execution and performance of relevant agreements or other written documents with you;

(8) Other circumstances stipulated by laws and regulations.

5. How to manage your personal information

You can access and manage your personal information in the following ways:

5.1 Access, modify or supplement your personal information

(1) You can access, correct and supplement your personal information through the "Personal Settings" page in accordance with our relevant policies and prompts.

(2) You may also access, correct and supplement your personal information through your company administrator in the background of the software.

5.2 Delete your personal information

In the following circumstances, you may request your company administrator to delete personal information:

(1) If your company violates laws and regulations in the handling of personal information;

(2) If your company collects and uses your personal information without your express consent;

(3) If our handling of personal information seriously violates the agreement with you;

(4) If your company no longer uses our products or services, or if your company administrator actively cancels your account in the background of the software;

5.3 Account cancellation/deletion

Under the conditions agreed in the user service agreement and relevant national laws and regulations, your account may be cancelled or deleted. After the account is cancelled or deleted, all information and data related to the account will be deleted or processed.

Account cancellation method: My-Personal Settings-Cancel account, or contact the platform customer service for you to cancel.

(1) Once your account is cancelled, it will not be restored. You will not be able to log in to the account or use related products and services through the account. Please make sure to back up all information and data related to the account before operation.

(2) After account cancellation, you will not be able to recover and access all the data information in the account, including but not limited to personal data, usage information, etc.

(3) After account cancellation, even if you register and use the relevant products and services again with the same mobile phone number or email address, the account will be regarded as a new user account by default.

(4) The cancellation of the account does not mean that any form of exemption or mitigation of the acts and relevant responsibilities before the cancellation of the account.

5.4 Change the scope of your authorization and consent

While some information is necessary for using our services, most other data collection is at your discretion. You may choose to limit the scope of information we collect or revoke your authorization by deleting data, disabling device features, or other methods. Importantly, revoking authorization wont affect any data processing activities that were already conducted under your previous consent.

We generally do not charge fees for your reasonable requests. However, we may charge appropriate costs for repeated requests that exceed reasonable limits. Requests that are unwarranted repetitions, require excessive technical effort (such as developing new systems or fundamentally altering existing practices), pose risks to others legitimate rights and interests, or are otherwise impractical may be denied.

Under the following circumstances, we will not be able to respond to your requests for access, modification or supplement, deletion, cancellation or change of consent and authorization in accordance with legal and regulatory requirements:

(1) those directly related to national security and defense security;

(2) Those directly related to public security, public health or major public interests;

(3) those directly related to criminal investigation, prosecution, trial and execution of judgment;

(4) There is sufficient evidence to show that you have subjective malice or abuse your rights;

(5) The response to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

(6) Those involving trade secrets;

(7) Other circumstances stipulated by laws and regulations.

6. How we will protect and preserve your personal information

We take the security of your personal information very seriously. We use industry-standard practices to protect your personal information from unauthorized access, disclosure, use, modification, damage or loss. We will take all reasonable and feasible measures to protect your personal information.

We will take all reasonable and feasible measures to ensure that no personal information unrelated to our services is collected. While we make every effort to protect your personal data, please understand that due to technological limitations and potential malicious activities in the internet industry, complete security cannot be guaranteed at all times. You should be aware that the systems and communication networks you use to access our services may encounter issues caused by factors beyond our control. Please note that the information you voluntarily share or publicly disclose when using our services may involve personal information or sensitive data related to you or others. We urge you to exercise greater caution when considering whether to share or publicly disclose such information while using our services.

In the event of a personal information security incident, we will promptly inform you in accordance with legal and regulatory requirements, covering: the incidents basic details and potential impacts, measures we have implemented or will take to address the situation, recommendations for risk prevention and mitigation, and remedial actions available to you. We will notify you through email, letters, phone calls, push notifications, or other communication methods. When individual notification is impractical, we will issue public announcements through appropriate channels. Additionally, we will proactively report the incidents resolution status to regulatory authorities as required by applicable regulations.

The personal information we collect and generate within the Peoples Republic of China will be stored in China. We will retain your personal information only for as long as necessary to achieve the purposes outlined in this policy. However, to comply with applicable laws and regulations, court judgments or rulings, requirements from other competent authorities, or public interest considerations, we may appropriately extend the retention period.

7. Third-party providers and their services

To ensure a smooth browsing experience, you may receive content or web links from third parties (hereinafter referred to as "third parties") outside of us and our partners. We have no control over such third parties. You may choose whether to access the links, content, products and services provided by third parties.

We have no control over third parties privacy and personal information protection policies, and such third parties are not bound by this policy. Before submitting your personal information to a third party, please ensure that you have read and approved the privacy protection policies of such third parties.

8. How we handle the personal information of minors

We encourage parents or guardians to guide minors under the age of eighteen in using our services. We recommend that parents or guardians review this policy and that minors obtain parental consent and guidance before using our services or submitting personal information. If we discover and confirm that a minor has submitted personal information without parental consent, we will remove it promptly.

9. How this policy is updated and how it applies

This policy constitutes an integral part of the Software License and Service Agreement. We reserve the right to update or modify this policy at our discretion, and may notify you of such changes through various channels, including but not limited to website announcements and private message notifications. Without your explicit consent, we will not restrict your rights under this Privacy Policy. For significant revisions or modifications that substantially diminish your rights under this policy, we will provide more prominent notifications (including public announcements on our platform or pop-up alerts).

If you do not agree to the revised Privacy Policy, you have the right and should immediately cease using our services. If you continue to use our services, you will be deemed to have accepted the modifications we have made to the terms of this Policy.

This policy applies to all of our services. However, certain services have specific privacy policies that provide more detailed information on how we handle your information in those services. In the event of any conflict between this policy and the specific privacy policy of a particular service, the specific privacy policy shall prevail.

Other

1) The interpretation and dispute resolution of this User Privacy Policy shall be governed by the laws of mainland China. In case of any disputes arising from the execution or performance of this Policy, both parties shall first attempt to resolve them through friendly consultations. If no agreement is reached, either party may file a lawsuit with the competent Peoples Court at our registered address.

2) The headings of this User Privacy Policy are for convenience and reading only and shall not affect the meaning or interpretation of any provision in the text.