MIIVII is committed to protecting your privacy and personal information. This policy will inform you of our privacy practices and the way to protect your personal information. Please read this policy carefully before employing the products or services of MIIVII. Once you choose to use MIIVII’s products or services, it means that you acknowledge and accept all the content of this policy and agree that MIIVII can collect, use, save and share your information according to this policy. If you do not agree with any of the terms in this policy, you should immediately stop using the products or services of MIIVII. If you have any questions, comments or suggestions on the content of this policy, you can contact us by sending emails to BD@miivii.com.

How do we collect your personal information?

Personal information refers to the information recorded electronically or in other ways that can be used to identify a natural person’s identity when used alone or in combination with other information. Sensitive personal information refers to the personal information that, once leaked, illegally provided or misused, may endanger the personal safety and property, easily cause damage to personal reputation, physical and mental health, or lead to discriminatory treatment. For example, sensitive personal information includes ID number, personal biometric information, bank account, communication content, physiological health information, etc. Such data will be submitted directly to us when you use our website, products or services, as well as interact with us. For example, we may get your information when you create a MIIVII account or contact us for support; or through our records of how you interact with our website, products or services, for instance, via technologies such as cookies; or by receiving usage data from the software running on your device. The data we collect depends on the way you interact with MIIVII, including the websites you visit, the products and services you use, your name, gender, company name, job title, address, email address, phone number, login information (account and password), photos, certificate information, etc. We also collect the information you provide us with and the content of the messages you send us, such as the query information you enter or the questions or information you provide to obtain customer service support.

We only collect the information that is necessary for the realization of our product functions based on the principles of lawfulness, legitimacy and necessity. You may need to offer specific sensitive personal information to achieve specific functions when using some MIIVII products or services. If you choose not to provide such information, you may not be able to use certain functions normally, but this will not affect your use of other functions. If you voluntarily provide your sensitive personal information, you agree with us that we can process your sensitive personal information in line with the purposes and methods described in this policy.

How do we use the collected information?

We strictly abide by the provisions of laws and regulations and the agreement with users, and use the collected information for the following purposes. If we use your personal information beyond the following purposes, we will explain to you and ask for your consent.

1) Create an account.

2) Fulfill your transaction or service request, including fulfilling orders; delivering, activating or verifying products or services; participating in online or offline activities; making changes at your request or providing information you request (such as the marketing materials and white papers of products or services ); and provide technical support.

3) Contact you; send you information about the products and services that you may be interested in; invite you to participate in the activities held by MIIVII (like exhibition activities), market surveys, or satisfaction surveys; and send you marketing messages. If you do not want to receive such information, you can unsubscribe at any time.

4) Send you important notifications, such as those of the updates and installations of the operating system or applications.

5) Provide you with personalized user experience and personalized content.

6) Certify and manage suppliers and business partners, communicate or conduct business with them.

7)  Conduct internal audit, data analysis and research to improve our products and services.

8)  Analyze the business operation efficiency and measure the market share.

9)  Troubleshoot errors if you choose to send us error details.

10)  Synchronize, share and store the data you upload or download and perform the data that are required when you upload and download information.

11)  Protect the safety of our products, services and customers or users, implement and improve our loss prevention and anti-fraud plans.

12)   Comply with and perform applicable legal requirements, relevant industry standards or our policies.

MIIVII may also collect and use anonymous data. Anonymous data refers to the data that cannot be used to determine an individual’s identity. For example, MIIVII collects aggregated statistics, such as website visits. MIIVII’s collection of such data aims to understand how users employ their own websites, products and services. In this way, MIIVII can improve its services and better meet the needs of its customers. MIIVII may, at its discretion, collect, use, process, transfer or disclose the unidentified data for other purposes. We will do our best to isolate your personal information from the anonymous data, and apply them separately. If your personal information is mixed with the anonymous data, it will still be treated as your personal information.

MIIVII will comply with the requirements of applicable laws to deal with your personal information on the basis of appropriate legality, including:

· Processing your personal information in order to fulfill the contract when responding to your transaction or service request;

· Processing your personal information with your consent;

· Processing your personal information based on the legitimate interests of us or third parties, for the purpose of improving our products and services, implementing and improving our loss prevention and anti-fraud plans, etc. when contacting you, conducting marketing or doing market research. These legitimate interests include enabling ourselves to more effectively manage and operate our business as well as provide our products and services; protecting the safety of our business, systems, products, services, and customers; enabling our internal management to comply with the internal policies and processes; and other interests described in this policy;

· Processing your personal information based on the compliance with and the enforcement of legal obligations.

 How do we use Cookie and related technologies?

To ensure the proper functioning of our website, we sometimes store small data files called cookies on the computers or mobile devices. A cookie is a plain text file stored on a computer or mobile device by a web server. The content of the cookie can only be retrieved or read by the server that created it. Each cookie is unique to your web browser or mobile application. Cookies usually contain identifiers, site names, some numbers and characters. With the help of Cookie, the website can store data like users’ preferences or the items in their shopping baskets.

The purpose of enabling Cookie by MIIVII is the same as that of using it by most websites or internet service providers, which is to improve the users’ experience. With the help of Cookie, the website can remember the users’ single visit (using a session cookie) or multiple visits (using permanent cookies). With the help of Cookie, the website can save settings such as the language, font size, and other browsing preferences of computers or mobile devices. This indicates that users do not need to reset their preferences every time they visit. If a website does not use Cookie, the website will treat the user as a new visitor every time he/she opens the page. For example, if you log in to a website and then turn to another page, the website can not recognize you, and you will be logged out again. MIIVII will not use Cookie for any purposes other than those described in this policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer. Most web browsers possess a function to block cookies. However, if you do this, you will need to change your user settings by yourself each time you visit our website.

In addition to Cookie, we also use other similar technologies such as web beacon and pixel tag on our websites. For example, the email sent to you by MIIVII may contain a click URL that links to the content of MIIVII’s website. If you click on that link, MIIVII will track the click, which helps us better understand your product and service preferences as well as improve our customer service. Web beacon is usually a transparent image that is placed on a website or in an email. With the help of the pixel tag in the email, we can know whether the email is opened. If you do not want your activities to be tracked in this way, you can unsubscribe it from MIIVII’s mailing list at any time.

Your use of our website means that you agree to the use of cookies, web beacons and pixel tags as mentioned above.

How do we disclose your personal information?

In cases where certain services are provided by the authorized partners of MIIVII, we will share your personal information with our partners according to this policy. For example, when you buy MIIVII’s products online, MIIVII must share your personal information with the logistics service providers to arrange the delivery, or ask for the partners to provide services. MIIVII will require the partners to process the above information for us in accordance with our instructions, privacy policy and other related confidentiality and security measures, and for the following purposes: 

· Provide you with our services;

· Achieve the purposes stated in the section of “How do we use the collected information”;

· Fulfill our obligations in the Service Agreement or this policy and exercise our rights;

· Understand, maintain and improve our services.

If we share your information with the above-mentioned third parties, we will adopt encryption, anonymization and other means to protect your information.

In cases when we apply to legal requirements or respond to legal procedures, MIIVII may also disclose your personal information to relevant law enforcement agencies or other government agencies. In certain jurisdictions, if MIIVII is involved in reorganization, merger, bankruptcy or liquidation litigation, your personal information may also be disclosed to the transaction party. MIIVII will also disclose your data when there is a reasonable demand, such as for the execution of the contract, and we believe that it is necessary and appropriate to disclose your information in order to prevent physical damage or property loss as well as investigate possible or actual illegal behaviors.

How do we get access to or modify your personal information?

MIIVII will do its best to maintain the accuracy and completeness of the personal information and update these data in a timely manner.

Based on the applicable laws, you may

(1) Have the right to visit the specific personal information we hold about you; 

(2) Ask us to update or correct your inaccurate personal information; 

(3) Refuse or restrict us from using your personal information;

(4) Require us to delete your personal information.

If you want to exercise the relevant rights, please let us know in time. To ensure the security, you may need to provide a written request and verify your identity. If we have reasonable grounds to believe that your requests are deceptive, unfeasible, or may invade the privacy of others, we will refuse to process them. Please understand that due to technical limitations, legal or regulatory requirements, we may not be able to meet all your needs, but we will respond to your requests within a reasonable period of time.

Based on the applicable laws, when MIIVII processes your personal information with your consent, you also have the right to revoke your consent at any time. However, withdrawing consent will not affect the legitimacy and effectiveness of our processing of your personal information based on your consent before revocation, nor will it affect our processing of your personal information on the basis of other appropriate justifications.

If you believe that our processing of your personal information does not comply with the applicable data protection laws, please contact us through the contact details listed in this policy.

How will we protect and keep your personal information?

MIIVII attaches great importance to the security of personal information. We use appropriate physical, administrative and technical safeguards to protect your personal information from unauthorized visits, disclosure, use, modification, damage or loss. For example, we will use a protection mechanism to prevent malicious attacks on data; deploy an access control mechanism to ensure that only authorized personnel can access personal information; do our best to protect your personal information, but please note that any security measures can not be impeccable.

We will keep your personal information within the time limit required to achieve the purposes stated in this policy, unless the retention period needs to be extended in accordance with legal requirements or approval, or permitted by law. The storage period of data may be different based on different scenarios, products and services. The standards we use to determine the retention period include: the time required to retain personal information for the purpose of the business, such as providing products and services, maintaining corresponding transaction and business records, controlling and improving the performance and quality of products and services, ensuring the safety of systems, products and services, dealing with possible user queries or complaints, positioning problems, etc .; whether the users agree to a longer retention period; whether the laws, contracts, etc. have special requirements for data retention. As long as your account needs to provide you with necessary services, we will retain your registration information. You can also choose to cancel your account. After you cancel your account, we will stop providing products and services for your account, and remove or anonymize your corresponding personal information without special legal requirements.

How do we handle children’s personal information?

Our products, websites and services are mainly for adults. Without parents’ or guardians’ consent, children could not create their own user accounts. For the collection of children’s personal information with parental consent, we will only use or disclose the data only if permitted by law, with the explicit consent of the parents or guardians, or necessary to protect the children. If MIIVII finds that it has collected the children’s personal information without prior verifiable parental consent, it will try to delete the relevant data as soon as possible.

Third-party providers and their services

In order to ensure a smooth browsing experience, our website or services may provide links to third-party applications, products, services or websites. MIIVII has no control over those third parties. You can choose whether to access the links, content, products and services provided by third parties.

MIIVII cannot control the privacy and data protection policies of the third parties, and such third parties are not subject to this policy. It is recommended that you review the privacy policy before allowing any websites that interact with you to collect and use your personal information.

About policy updates

MIIVII reserves the right to update or modify this policy from time to time. If our privacy policy changes, we will post the latest version of the privacy policy here.

Contact us

If you have any privacy complaints or questions about MIIVII, you can send emails to us:bd@miivii.com

When MIIVII processes your personal information in accordance with this privacy policy, MIIVII entity that responds to your request, contacts you, provides products or services for you, or has concluded a contract or is about to reach one with you is the controller of relevant personal information.

Last updated date: April 24th , 2020