Chuanjun Privacy Statement and Practices

Privacy Statement and Practices

Terms used herein but not otherwise defined shall have the meanings ascribed to them in Section 19 of this Privacy Statement. This Privacy Statement is also known as our Privacy Policy and references to our Privacy Policies in our other documentation shall be a reference to this Privacy Statement.

At Chuanjun, we value your privacy. Regardless of whether you are our customer, a visitor to one of our Websites or Facilities, or someone we deal with in the ordinary course of our business, protecting your privacy is important to us and is a responsibility that we take seriously. We understand the importance of ensuring that we collect, use, store, share and dispose of Personal Data in a fair, ethical, transparent, secure, and lawful way.

This Privacy Statement describes the privacy practices we have adopted to protect your Personal Data and to be compliant with regulations pertaining to privacy and data protection.

Chuanjun Information Technology (Beijing) Co., Limited and its direct and indirect wholly owned and controlled subsidiaries are the data controller(s) of your Personal Data.

Privacy Statement

This Privacy Statement applies to Chuanjun and is addressed to individuals outside our organization with whom we interact with in respect of our business, including our customers, prospective customers, job applicants, users of our Websites or Facilities, and other third parties who provide information to us through various other channels (together, “you”).

Your use of our Websites is subject to our Terms of Use, which sets forth important information about your use of our Websites. We will obtain your consent to collect, use, share, transfer (including but not limited to overseas transfer), disclose or otherwise process your Personal Data (which term shall be deemed to include reference to Sensitive Personal Data) if and to the extent required by the applicable laws. Where required, we will obtain your explicit and/or separate consent for Processing of your Personal Data, including but not limited to disclosing your Personal Data to any third parties, overseas transfer of your Personal Data, direct marketing, Processing of your Sensitive Personal Data, etc. (if any).

This Privacy Statement may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data. In case of material changes, we will seek your consent to these changes as required by applicable law. We encourage you to read this Privacy Statement carefully, and to regularly check this page to review any changes we might make to the same.

If you have any questions about how we Process your Personal Data, or would like to lodge a complaint, please contact us at confidential@chuanjunnet.cn.

Collection of Personal Data

Summary: We collect or obtain Personal Data from you from different sources, including automatically as you use our Websites or Services; when you contact us or request information; during the course of our relationship with you (or your employer); when you make Personal Data public; when you register to use any of our Services; or when you interact with our third party content or advertising partners on their websites. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities, research providers, and financial institutions).

How we collect and Process Personal Data can vary based on how and why you interact with us. Namely, we Process Personal Data as follows:

Information We Collect Directly from You. When you communicate or do business with us, we collect information from you, and this may include personal information. For example, we collect information from you when you buy our Services, create an online account with us, request information from us, download information from our Website, submit a trouble ticket, access our Facilities, participate in a contest or survey given by us, attend any of our customer or marketing events, or otherwise engage with us in relation to a Service.

Information We Collect Automatically. We automatically collect information about your use of our Websites or online Services through cookies, web beacons, log files and other technologies (including geotagging). We may use this information in aggregated form, or we may associate it with your username and other personal information that we collect about you. We may also combine information collected about you on one of our Websites with information collected through other means for the same purposes as we would use such information in non-combined form. Please see the section “Our Use of Cookies and other Tracking Mechanisms” below for more information.

Information About Your Use of Our Services. Where permitted, we also collect information about your use of our Services, Facilities and Websites, including power utilization, capacity usage, traffic data, CCTV images, security data, and your access rights and privileges (e.g., credentials supplied, biometric data, etc.).

Information We Collect from Third Parties. In addition, we may collect or obtain your Personal Data directly from third parties. These third parties typically consist of research service providers, credit agencies, and law enforcement agencies. Where permitted, we may combine this data with information that we already maintain about you.

We will seek your separate consent for Processing of your Sensitive Personal Data (if any) and implement appropriate protective measures to safeguard your Sensitive Personal Data.

You can choose not to provide Personal Data to us in certain circumstances. However, please note that if you decline to provide us with your Relevant Personal Data and such information is necessary for us to provide Services to you, or for you to access our Websites or Facilities, or to perform administrative functions in respect of the same (e.g., billing, customer support, etc.), we may be unable to do these things for you.

Type and Categories of Personal Data

Summary: The type and categories of Personal Data we collect and Process may include, but is not limited to: your personal details (e.g., your name, age, and gender); demographic data (e.g., your location and language preferences); your contact details (e.g., your telephone number and email address); records of your consents; work order details; information about our Websites (e.g., the type of device you are using); details of your employer; information about your interactions with our content or advertising; and any views or opinions you provide to us.

PLEASE NOTE: We do not process personal information or data on behalf of our customers, and we do not have access to (nor monitor) our customers’ data which (i) is stored or processed by them on their servers or systems within our Facilities or (ii) otherwise transits over or through our Network Services.

We Process the following type and categories of Personal Data:

Personal Details: given name(s), family name, preferred name, age, and gender, birthdate, ID

Demographic Information: salutation, job title, and language preferences, marital status, nationality

Contact Details: correspondence and business address, telephone number, email address, details of personal/executive assistants (where applicable), messenger application preference, online messaging details, and social media details

Consent Records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent (i.e., for credit checks, background checks, etc.).

Access Records: dates, times and locations of access to our Websites or Facilities; access credentials, including any location data or biometric data you choose or consent to provide to us.

Work Order Details: records of work orders placed on our Customer Portal.

Data Relating to Our Websites: your device type, operating system, browser type, browser settings, IP address, language settings, date and time of connecting to a Site, usage data, and aggregate statistical information; as well as your Customer Portal usage statistics (including settings, dates and times of connecting to the Customer Portal and other technical communications information such as username, password, security login details).

Employer Details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer.

Content and Advertising Data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.

Job Applicants: education details, job and salary history, marital status, information relating to dependents, details of bank account and other information gathered during the interview process.

Purposes of Processing

Summary: We Process Personal Data for various reasons, including but not limited to providing you with access to our Websites, Customer Portal, and Services; communicate with you; manage our IT systems in connection with our business; ensuring health and safety of all our customers, employees, and allow access to our Facilities.

Subject to applicable laws, we Process Personal Data for the following purposes:

To provide our Services to you, to communicate with you about your use of our Services, and to fulfil your orders for additional Services (including via email, telephone, audio or video conference, text message, social media, post or in person).

To provide secure access to our Facilities, including by means of secure access systems which processes your Personal Data, including any access credentials and any biometric data you may choose to provide for these purposes.

For the purpose for which you specifically provided the Personal Data to us, including, to respond to your inquiries, provide information that you requested, address trouble tickets, and provide you with support in respect of your Services.

To deliver customized content to you, offer location based, personalized help and instructions, and otherwise personalize your experience while using our Websites or our Services.

To better understand how users access and use our Websites and Services, both on an aggregated and individualized basis, to administer, monitor, and improve our Websites and Services, for our internal purposes, and for other research and analytical purposes.

For marketing and promotional purposes (e.g., we may use your Personal Data to contact you with newsletters, special offers and promotions, or to otherwise about products or information we think may interest you, as well as to track the success of our marketing and advertising campaigns).

To assist us in advertising our products and services in various mediums including, without limitation, sending promotional emails, advertising our services on third party websites and social media platforms, direct mail, and by telemarketing.

To undertake health and safety assessments and related compliance activities (including record keeping) in order to ensure a safe and secure environment to all individuals working or present at our Facilities.

To protect our customers, employees, or property, including management, monitoring and operation of our IT and security systems — for instance, to investigate fraud, harassment or other types of unlawful activities involving third parties that we do business with, and to enforce this Privacy Statement, as well as our Terms of Use.

For our recruitment activities, including interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.

The legal basis for the Processing of Personal Data carried out in accordance with the purposes described above is as follows:

Contractual purposes – if our processing of your personal data is objectively necessary for the performance of any contract and obligations before and after the contract, as well as specific legal obligations arising from the performance of the contract, then we rely on the legal basis of “contractual necessity” for the processing.
Legal purposes – if our processing of your personal data is for the fulfilment of legal and tax obligations relating to the sale, then we rely on the legal basis of “legal obligation” for the processing
Consent – we will obtain your consent where required by the applicable law.

We will obtain your consent if we would like to Process your Personal Data for purposes other than those stated in the Privacy Statement.

Automated decision making

Any analytics or evaluation based on computer program around behavior, interests, hobbies, credit information, health or decision-making activities, are transparent, open and fair, and do not apply any differential treatment between individuals.

You may opt out of customized or personalized marketing conducted based on automated decision making. You may also request us to provide an explanation on any decisions that may materially impact you based on automated decision making, and deny our decision made solely based on automated decision making.

Disclosure of Personal Data to Third Parties

Summary: We may disclose Personal Data to third parties, including but not limited to, legal and regulatory authorities, our external advisors, our Processors, and any third-party that as necessary in connection with: the provision of our Services to you, legal proceedings where the Personal Data may be relevant, and for investigating, detecting, or preventing criminal offences.

PLEASE NOTE: We do not sell Personal Data to third parties.

To the extent permitted by law, with your separate consent, we may share your information as follows:

Fesco 北京外企人力资源服务有限公司 Beijing Foreign Enterprise Human Resource Service Co., Ltd.

Contact: 北京市朝阳区朝阳门南大街14号 14 Chaoyangmen South Street, Chaoyang District, Beijing, +86 10 8569 1286
Purpose of use of personal information by the person receiving personal information: Payroll, bookkeeping and tax related services on behalf of Chuanjun
Means and Method of Disclosure: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required
Categories of personal information transferred: For Employees and candidates for employment: name, age, bank account details, employee ID, dependents, passport, family relation certificate, employment agreement, contact information (phone, address, email, etc) and salary information. For suppliers and third parties: Any details included on invoices, including VAT number, bank details, transaction details related to the goods and services acquired by or from Chuanjun.

北京外企德科人力资源服务上海有限公司 Fesco Adecco Human Resources Service Shanghai Co., Ltd.

Contact: 上海市黄浦区中山南路28号久事大厦附楼 Annex building, Jiushi Building, No. 28, Zhongshan South Road, Huangpu District, Shanghai, +86 21 6358 9999
Purpose of use of personal information by the person receiving personal information: Payroll, bookkeeping and tax related services on behalf of Chuanjun.
Means and Method of Disclosure: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required
Categories of personal information transferred: For Employees: name, age, bank account details, employee ID, dependents, passport, family relation certificate, employment agreement, contact information (phone, address, email, etc) and salary information. For suppliers and third parties: Any details included on invoices, including VAT number, bank details, transaction details related to the goods and services acquired by or from Chuanjun.

首优咨询（北京）有限公司First Advantage (Beijing) Co., Ltd

Contact: 北京市朝阳区酒仙桥路甲16号新港大厦1118室, Room 1118, New Port Tower, No. 16, Jiuxianqiao Road, Chaoyang District, Beijing, 010 65505506
Purpose of use of personal information by the person receiving personal information: To conduct reference checks for hiring purpose
Means and Method of Disclosure: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required
Categories of personal information transferred: name, telephone number, email address, ID, nationality, address, working experience, contact and employment information (including details of compensation) relating to previous employment education history and proof For suppliers and third parties: Any details included on invoices, including VAT number, bank details, transaction details related to the goods and services acquired by or from Chuanjun.

上海开源智造软件有限公司OS Consulting Group Limited

Contact: 上海市杨浦区国定东路200号2号楼5层 5th Floor, Building 2, No. 200, Guoding East Road, Yangpu District, Shanghai
Purpose of use of personal information by the person receiving personal information: To conduct business workflow testing in Chuanjun’s ERP system
Means and Method of Disclosure: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required
Categories of personal information transferred: Contact Details: correspondence and business address, telephone number, email address, Work Order Details: records of work orders placed on our Customer Portal. Data Relating to Our Websites: your device type, operating system, browser type, browser settings, IP address, language settings, date and time of connecting to a Site.

Other Purposes for Which We May Seek Your Consent: From time to time, we may seek your consent to use your Personal Data for a purpose not described in this Privacy Statement, which may include the consent to share such Personal Data with third parties.

Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research, or similar purposes.

If we engage a third-party “Processor” to Process your Personal Data, we will ensure the contract between us and the third-party Processor contains adequate provisions to (i) restrict their ability to Process the Personal Data only in accordance with our prior written instructions, and (ii) ensure adequate measures to protect the confidentiality and security of the Personal Data.

Communications and Marketing

With your consent, we may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take several days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested or received from us.

Cross Border Transfers of Personal Data

We may, with your explicit and separate consent, transfer your Personal Data to recipients located outside of China, and your Personal Data may be stored in or accessed from outside of China, pursuant to legally acceptable mechanisms that are aimed at ensuring an adequate level of protection as regards your Personal Data under applicable laws, including but not limited to putting in place appropriate contractual agreements with the data recipients, and any other necessary measures to ensure the data recipient’s data processing activities comply with standards comparable to those set out under the applicable PRC laws and regulations. We provide below the relevant information in relation to the cross-border transfer of your Personal Data:

Digital Edge (Singapore) Pte. Ltd.

Country to which personal information is transferred: Singapore
Contact detail: 6 Temasek Boulevard, #10-05, Suntec Tower Four, Singapore 038986 / john@digitaledgedc.com
Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required
Categories of personal information transferred: E-mail address, encrypted password(s), name(s), phone numbers, registered social media (Line, WhatsApp, LinkedIn, etc.), address, and services acquired.
Purpose of use of personal information by the person receiving personal information: Storage and management of collected personal information of customers and potential customers, Hosting and IT support, Business support – central support functions (service support, billing, customer communications, marketing, hiring of potential candidates and undertaking background checks, etc).
Period of retention and use of personal information by the person receiving personal information: Retain in accordance with data retention policy (except where it is necessary to retain personal information under the relevant laws and regulations).

Digital Edge (Hong Kong) Limited

Country to which personal information is transferred: Hong Kong
Contact detail: Level 24, Central Plaza, 18 Harbour Road, Wan Chai, Hong Kong / john@digitaledgedc.com
Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required
Categories of personal information transferred: E-mail address, encrypted password(s), name(s), phone numbers, registered social media (Line, WhatsApp, LinkedIn, etc.), address, and services acquired.
Purpose of use of personal information by the person receiving personal information: Same as above.
Period of retention and use of personal information by the person receiving personal information: Same as above.

Cloudstaff Pty Ltd

Country to which personal information is transferred: Australia | Philippines
Contact detail: Level 11, 1 Margaret Street, Sydney, NSW 2000/ jaehyunl@cloudstaff.com
Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network right away
Categories of personal information transferred: Name, Surname, Address, Email Address, Telephone no., IP address, data collected on Customer Portal (Odoo.com).
Purpose of use of personal information by the person receiving personal information: Customer support service via chat service. Our Helpdesk staff and engineers may access this information in a limited and reasonable manner in order to solve any issue with our services, or at your explicit request for support reasons, or as required by law, or to ensure the security of our services in case of violation of our Acceptable Use Policy in order to keep our services secure.
Period of retention and use of personal information by the person receiving personal information: 2 years

Odoo Limited

Country to which personal information is transferred: Singapore (production server) and Canada and France (backup server)
Contact detail: Odoo S.A. – Data Protection, Chaussée de Namur, 40

1367 Grand Rosière, Belgium | privacy@odoo.com

Privacy Policy: https://www.odoo.com/privacy
Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required
Categories of personal information transferred: Email address, name, postal address, telephone number(s), IP addresses, job applications (and if we decide to send you a job offer, we will also ask you to provide extra personal details as required to fulfill our legal obligations and personnel management requirements), browser language and geolocation.
Purpose of use of personal information by the person receiving personal information: Odoo does not use the personal data directly, but provides cloud-based ERP Software as a service to Chuanjun which will use the data to support sales, operations, and billing services for our customers and manages our Human Resource Information System, including our recruiting process.
Period of retention and use of personal information by the person receiving personal information: Information will be stored on the supplier’s server as long as the business need and will be accessed by Chuanjun’s personnel only

Metabase, Inc.

Country to which personal information is transferred: Virginia, USA
Contact detail: 660 4th Street, #557, San Francisco, CA 94107 / legal@metabase.com
Privacy Policy: https://www.metabase.com/privacy/
Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required
Categories of personal information transferred: Email address, name, postal address, telephone number(s), IP addresses, browser language and geolocation and other anonymized data which can be found at: https://www.metabase.com/docs/latest/information-collection.html.
Purpose of use of personal information by the person receiving personal information: Metabase does not use the personal data directly but provides cloud-based business intelligence/data visualization software as a service to Chuanjun which will use the data to support decision making and operations. Metabase uses anonymized data to improve on the products and services offered to Chuanjun.
Period of retention and use of personal information by the person receiving personal information: Information will not be stored on Metabase’s servers – once the service or script is complete, the information is deleted and no longer stored or accessible on Metabase’s servers.

Trustifi LLC

Country to which personal information is transferred: Singapore
Contact detail: Trustifi LLC, 6543 S Las Vegas Blvd, Las Vegas, NV 89119
Telephone: +1-(844) 235-0084
Email: support@trustificorp.com
Privacy Policy: https://www.trustifi.com/privacy-policy-2/
Time and method of transfer of personal information: Personal information is protected for both in transit and in rest by market standard’s encryption
Categories of personal information transferred: E-mail address, E-mail content, Names and email addresses of senders/ recipients of emails; Photographs, images, and videos; Device identifiers – such as the Internet Protocol (IP) address and other types of unique device identifiers. Personal information which is collected and processed by Trustifi may also include sensitive data, which may reveal your ethnic origin, health data, religion, sexual orientation, etc.
Purpose of use of personal information by the person receiving personal information: Scan and encrypt files and email content to identify and filter out potential phishing attempts and viruses. As part of the scanning process, Trustifi may have access to various types of personal information set forth above, however, they will only use and process such information for the sole purpose of providing the services to Chuanjun (namely anti-phishing and anti-virus scanning).
Period of retention and use of personal information by the person receiving personal information: For as long as necessary to provide the services to Chuanjun, and as necessary to comply with Trustifi’s legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

Microsoft Regional Sales Pte Ltd.

Country to which personal information is transferred: Hong Kong and Singapore
Contact detail: Microsoft EU Data Protection Officer, One Microsoft Place, South County Business Park, Leopardstown Dublin 18 D18 P521, Ireland
Telephone: +353 (1) 706-3117
https://www.microsoft.com/en-hk/concern/privacy
Privacy Policy: https://privacy.microsoft.com/en-US/
Time and method of transfer of personal information: Data is transferred to supplier’s servers in encrypted tunnel and stored on the server with industrial lead encryption algorithm. The information will be transferred to the server from time to time.
Categories of personal information transferred: Email address, name, postal address, IP address, email content, Personal information may also include sensitive data, which may reveal your ethnic origin, health data, religion, sexual orientation, etc.
Purpose of use of personal information by the person receiving personal information: Microsoft provides cloud-based office suite used by Chuanjun, consisting of client software applications and connected experiences designed to enable customers like Chuanjun to create, communicate, and collaborate more effectively.
Period of retention and use of personal information by the person receiving personal information: Information will be stored on Microsoft’s server as long as necessary to provide the products and fulfill the transactions requested by Chuanjun, or for other legitimate purposes such as complying with its legal obligations, resolving disputes, and enforcing its agreements with Chuanjun. Because these needs can vary for different data types, actual retention periods can vary significantly.

PT. Nuroho Software Consulting

Country to which personal information is transferred: Singapore
Contact detail: Jl. Margorejo Indah XV, Margorejo, Kec. Wonocolo, Kota SBY, Jawa Timur 60238, Indonesia
Telephone: +62(811)353-9003
https://nurosoft.id/
Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required
Categories of personal information transferred: Contact Details: correspondence and business address, telephone number, email address, Work Order Details: records of work orders placed on our Customer Portal. Data Relating to Our Websites: your device type, operating system, browser type, browser settings, IP address, language settings, date and time of connecting to a Site.
Purpose of use of personal information by the person receiving personal information: For PT. Nuroho Software Consulting to conduct business workflow testing.
Period of retention and use of personal information by the person receiving personal information: Information will not be stored on Nuroho Software Consulting’s servers – once the service or script is complete, the information is deleted and no longer accessible by PT. Nuroho Software Consulting

You may exercise your data subject rights as specified in Section 13 of the Privacy Statement.

Third-Party Links

Our Websites may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Privacy Statement but is instead governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Our Websites may also include social media plugins such as “like” and “share” buttons. By clicking on such a plugin, the data you want to “like” or “share” will be provided to the relevant social media site. We are not responsible for the practices of such third-party social media sites once you have clicked on any such button. We will not collect any data about you from social media sites.

Data Security

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk, and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

Data Accuracy

We take every reasonable step to ensure that the Personal Data that we collect about or from you is accurate and, where necessary, kept up to date. If any of your Personal Data is inaccurate (having regard to the purposes for which it was collected and Processed), we take necessary steps as is required to ensure that such inaccurate data is erased or rectified without delay.

From time-to-time, we may ask you to confirm the accuracy of your Personal Data.

Data Minimization

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Privacy Statement.

Data Retention

We will keep your Personal Data for as long as necessary for the fulfillment of the purpose for which it is used, unless applicable law permits or requires a longer retention period.

Once the foregoing retention period expires, we will either (i) permanently delete or destroy the relevant Personal Data; or (ii) anonymize the relevant Personal Data so that it is no longer considered Personal Data under relevant laws.

Your Rights

Subject to applicable law, you may have the following rights regarding our Processing of your Personal Data:

Right to be informed. You have a right to know what Relevant Personal Data we have about you, what we do with it, where we get it from, who we share it with, how long we keep it and why we need it.

Right of Access. The right to request access to, or copies of, your Relevant Personal Data.

Right of Rectification. The right to request rectification of any inaccuracies in your Relevant Personal Data.

Right of deletion where permitted by the applicable law.

Right to Data Portability. The right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable and practicable.

Right to Withdraw Consent. Where we Process your Relevant Personal Data on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal and does not prevent the Processing of your Relevant Personal Data in reliance upon any other available legal basis).

Right to Complain. The right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority.

Right to Restrict Use. You have the right to limit the way we Process your Relevant Personal Data.

Right to Challenge Automated Decisions. You have the right to query and review decisions made about you using purely automated means (i.e., without human involvement or intervention) based on your Relevant Personal Data. You have the right to deny our decisions made solely by means of automated decision-making.

The forgoing rights are not intended to limit your statutory rights. To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Statement, or about our Processing of your Relevant Personal Data, please send an email to confidential@chuanjunnet.cn. Please note that in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights. In addition, where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request promptly, before deciding what action to take. In addition, where permitted under applicable law, we may charge you a reasonable fee to access your Relevant Personal Data, however, we will advise you of any fee in advance of providing you access.

Our Use of Cookies and other Tracking Mechanisms

When you visit our Websites, we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Data through Cookies and similar technologies, in accordance with our Cookie policy.

Direct Marketing

We Process Personal Data to contact you via email, telephone, direct mail, or other communication formats to provide you with information regarding services that may be of interest to you. If we provide our services to you, we may send information to you regarding our services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances, we will continue to contact you to the extent necessary for the purposes of any services you have requested.

Third-Party Ad Networks

We may use third parties such as network advertisers to display advertisements about Chuanjun on third party websites. Network advertisers display advertisements on third-party sites, based on your visits to our Websites as well as other websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested.

Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads, to personalize advertising content to you, and to track your movements on our Websites and on other third-party sites. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, and not this one. We may provide these third-party advertisers with de-identified information about your usage of our Websites and our Services, as well as aggregate information about visitors to our Websites and users of our Services; however, we do not share your personal information with these third parties.

You may opt-out of many third-party ad networks. For more information regarding this practice, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by, please visit their respective websites.

Children’s Privacy

We do not Process any Personal Data of children under the age of 14.

Details of Controllers

If you have any questions or inquiries in relation to this Privacy Statement, or would like to exercise your data subject rights, please direct your questions, inquiries, or requests to:

Zhou Feng

Tel: + 8621 80135120

Email: confidential@chuanjunnet.cn

Address: 2337-2342, Level 23, 5 Corporate Avenue ,150 Hubin Road, Huangpu District ,Shanghai, China 200021

Definitions

“Chuanjun”, “we”, “us”, “our” means Chuanjun Information Technology (Beijing) Co., Limited, and its direct and indirect wholly owned and/or controlled subsidiaries.

“Cookie” means a small file that is placed on your device when you visit a website (including our Websites). In this Privacy Statement, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.

“Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

“Customer Portal” means any online portal that provides information or interactive functionality.

“Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

“Facilities” means any of our offices and data centers and other property sites which we own, lease and/or operate in connection with our business.

“Network Services” means network connectivity services provided by us to our customers in connection with our data center services (e.g., cross connects, internet exchange and traditional voice, data and video connectivity services).

“Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual. Unless context otherwise requires, references to Personal Data in this Privacy Statement shall be deemed to include reference to Sensitive Personal Data.

“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

“Relevant Personal Data” means Personal Data in respect of which we are the Controller.

“Sensitive Personal Data” refers to data which, if breached, illegally provided or abused, may threaten personal or property safety and easily result in damage to personal reputation, or physical/mental health, or discrimination. Examples of Sensitive Personal Data include (but are not limited to) biometric data, religion, specific social status, medical health information, financial accounts, tracking/location information; and personal data of children 14 years of age or under.

“Services” means all products and services offered by Chuanjun, including Network Services, whether available online or offline.

“Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority.

“Websites” means any of the Chuanjun websites operated, or maintained, by us or on our behalf, including our Customer Portal (including any mobile version of such websites), whether operated under the Chuanjun brand or other name that we own.

Last updated: 19 August 2022