Lanxin (hereinafter referred to as "Lanxin" or "this product"), short for Lanxin Mobile (Beijing) Technology Co., Ltd. (hereinafter referred to as "we" or " the Company"), is an innovative Internet technology enterprise established in February 2014, and it specializes in the research and development of mobile internet and cloud computing technology products, and provides mobile application solutions for large and medium-sized enterprises in various industries and government information office. The company integrates modern office and information technology with the needs of enterprises and government users as the core, devotes itself to providing all-round and three-dimensional mobile application solutions for large-scale enterprises and government through the innovation of cloud computing and mobile internet technology based on the business interaction between PC and intelligent terminals, and thus helps enterprises and government to better achieve internal communication, mobile collaboration, efficient management and other needs in the Internet era, and improve own information construction.
As an Internet company, in addition to providing privacy protection for users, we have also put forward higher standards for our own security products to ensure that the products (or services) comply with the seven norms of "four-never & three-must" when using user information, namely:
1. Never look at what should not be seen.
2. Never disseminate what should not be disseminated.
3. Never store what should not be stored.
4. Never use what should not be used.
5. All behaviors must be explicit and respect the users' right to know and the right to choose.
6. All behaviors must be approved by the user.
7. All behaviors must be responsible for the collected privacy information of users.
This privacy policy will help you understand the following contents:
1. How we collect and use user information;
2. How we use Cookies and similar technologies;
3. How we store user information;
4. How we share, transfer and publicly disclose user information;
5. How we protect user information;
6. Protection of minors;
7. Changes and amendments to the privacy policy;
8. How to contact us;
9. Effectiveness of privacy policy.
Definitions:
Lanxin service provider: refers to the legal entity that develops and provides Lanxin products and services, i.e., Lanxin Mobile (Beijing) Technology Co., Ltd., hereinafter referred to as "we" or " the Company".
Lanxin client: refers to the program that corresponds to the server and provides local Lanxin service for customers, hereinafter referred to as the "client".
Lanxin Enterprise/Organization User: refers to the establishment, management and use of Lanxin services on behalf of the enterprise/organization after the enterprise or other organizations authorize administrators or directly register as Lanxin users through legal representatives and upload the address book of enterprise/organization employees through the Lanxin management platform as administrators to establish the enterprise/organization structure. Lanxin Enterprise/Organization Users shall include but be not limited to legal persons, government agencies, other organizations, partnerships or individual businesses, etc.
Lanxin Enterprise/Organization Administrator: refers to the Lanxin individual users who are authorized or designated by Lanxin Enterprise/Organization User and have the background operation authority of the management platform of Lanxin Enterprise/Organization User, and can open, manage and use Lanxin services on behalf of the enterprise/organization.
Lanxin Individual User: refers to the individual user who has registered Lanxin account, including the individual user with administrator rights of Lanxin Enterprise/Organization User and the personal user who is a member of Lanxin Enterprise/Organization User address book but without administrator rights of Lanxin Enterprise/Organization, hereinafter referred to as "You".
Personal Information: refers to various information recorded electronically or in other ways that can identify the identity of a specific natural person or reflect the activities of a specific natural person alone or in combination with other information.
Personal Sensitive Information: refers to the Personal Information that may endanger personal and property safety and easily lead to personal reputation, physical and mental health damage or discriminatory treatment once leaked, illegally provided or abused. The Personal Sensitive Information of Lanxin Service shall include the identification number, mobile phone number, personal biometric information, bank account number, property information, transaction information, personal information of children under 14 years old, etc.
Anonymization of Personal Information: refers to the process of making the subject of Personal Information unrecognizable and the processed information unrecoverable through technical processing of personal information.
Personal Information Controller: refers to an organization or individual that has the right to determine the purpose and method of Personal Information processing. Some of the Personal Information Controllers in the Lanxin Service of this Agreement are Lanxin Enterprise/Organization Users.
We hope to explain to you through this privacy policy how we collect, use, store, share, transfer and protect user information during the use of this product. Please read and understand this privacy policy carefully before using Lanxin, and use our products or services after confirming own full understanding and consent. Once you start using Lanxin, it means that you have fully understood and agreed to this policy, and allowed us to collect, use, store and share user information in accordance with this privacy policy. If you have any questions, comments or suggestions about the content of this policy, please contact us through the various contact methods provided by this privacy policy.
I. How we collect and use user information
We will collect and use user information for the following purposes described in this privacy policy:
(1) Realization of the basic functions of Lanxin
In order to provide Lanxin Service to You and Lanxin Enterprise/organization Users, to maintain the normal operation of Lanxin Service, improve and optimize our service experience and ensure your account security, we will collect information that you actively provide, authorize or provide based on the requirements of your company/organization, together with information generated when You use Lanxin Service and based on the following purposes and methods of this Policy:
1. Information to Register as Lanxin User
In order to register as a Lanxin User, so that we can provide You with basic Lanxin Service, such as IM chat (instant messaging), group creation, conference call, video conference, internet phone and other communication functions, You need to provide Your mobile phone number and SMS verification code to register and create a Lanxin Account, otherwise You will not be able to use Lanxin Service. After registering as a Lanxin User, You can further provide basic information, such as name, head portrait, gender, birthday, work area, corporate email, etc. If you only need to browse and search the Lanxin products, functions and service introductions displayed by the Lanxin official website, You do not need to register as a Lanxin User and provide the aforesaid information.
After registering as a Lanxin Individual User, You can modify Your Personal Information. The operation path is: [Mobile terminal--My--click Name or head portrait], and You can modify information such as nickname, phone number, birthday, region, etc.
When the Your enterprise/organization user cancels the Lanxin Account, we will anonymize or delete Your relevant Personal Information in that organization.
2. Information collected in the process of using Lanxin Service
When You use the Lanxin Service, in order to provide You with Lanxin intelligent hardware and/or software services that better meet Your needs, interactive display, search results, identification of abnormal account status, maintenance of normal operation of the Lanxin Service, improvement and optimization of Your experience of the Lanxin Service and protection of Your account security, the following information will be collected, including information on how You use the Lanxin Service and how You use it, and these information will be correlated:
Use information: We will collect the information submitted or generated when You use the Lanxin Service as an Lanxin Individual User, and the information submitted or generated when You use the Lanxin Service as an end user of Lanxin Enterprise/Organization User. If You need to recommend contacts registered with Lanxin on Your mobile phone address book through us so that You can add Lanxin friends or colleagues, You need to authorize us to access and collect Your information of mobile phone address book.
Device information: On the basis of the specific authorizations granted by you in installation and use of the software, we will receive and record information relating to the device used by you (e.g. device model, operating system version, unique device identifier and other information of software and hardware features) and the location of such device (e.g., IP address, GPS/Beidou location information, and any Wi-Fi access point, Bluetooth, base station and other sensor information).
Log information: when You use products or services provided by our clients, we will automatically collect Your detailed use of our services and save them as relevant weblogs, e.g., Your IP address, browser type, language used, access date and time, log approval information, attendance log information, etc.
Please note that the device information or log information alone is not sufficient to identify a certain natural person. If we combine such non-Personal Information with other information to identify certain natural person, or use the same in combination with Personal Information, then such non-Personal Information will be deemed as Personal Information during such combination, and we will anonymize and de-identify such Personal Information (unless we have your authorization or it is otherwise provided by laws and regulations).
If you choose to open and manage the Lanxin Service as Lanxin Enterprise/Organization Administrator, we will collect information and data (hereinafter referred to as "Enterprise Control Data") submitted or generated by Lanxin Individual User of Your Lanxin Enterprise/Organization User in the process of using Lanxin related functions/applications. The Enterprise Control Data may include:
The positions, subordinate departments, main industries, office email accounts, office telephones and other information assigned to You by Your organization, as well as the Personal Information such as geographical location, attendance clock-in, approval records, release log, schedule, working document and so on that You are required to provide or generate to complete the daily operation and management functions of Your organization.
Order and transaction information when You use Lanxin Service or purchase and open the third-party application services, so as to show You and facilitate Your order management. For example, the transaction information when You act as an Administrator and purchase Lanxin application service or third-party applications in Lanxin application market.
Other data submitted by enterprise/organization users that contain Your Personal Information, such as Lanxin enterprise address book information (including the information of employment, contact, personal identity, etc.)
You understand and agree that enterprise/organization users are the controllers of the above-mentioned Enterprise Control Data, and Lanxin Company will only open, manage and use the above-mentioned application services to process Your Personal Information/data subject to selection of the administrator of enterprise/organization user. Before enterprise/organization users uploading Personal Information such as communication information of Lanxin enterprise/organization and other Personal Information such as external business contact information of Lanxin Individual Users required by the enterprise/organization, they shall ensure that they have obtained the clear consent of Lanxin Individual User in advance, and only collect the end-user information necessary to realize the enterprise operation and management purposes, and have fully informed the end-user of the purpose, scope and usage of relevant data collection.
3. Information collected during Your use of the customized service
In order to provide You with better and more personalized services, such as providing more personalized but consistent services on different servers or devices, input recommendation, customer service reception or information push that better meet Your needs, understanding product suitability and identifying abnormal status of account numbers, we will collect relevant information about the services You use, including equipment information, logs and service usage information.
4. Information provided by the third party to us
We will collect information about You when performing operations related to You for other users, and may also obtain Your personal data information from Lanxin affiliates, cooperative third parties or through other legal channels. For example, in order to protect Your legitimate rights and interests, prevent risks such as fraud and gambling, and maintain the safe and stable operation of Lanxin Service and payment-related functions, we need to obtain the user identification information of the payment account You actually use from the third-party payment institution.
5. Information collected for other purposes
When we collect Your information for other specific purposes not stated in this policy, we will inform You in advance and seek Your consent.
The purpose of collecting and using the aforesaid information is to better manage Lanxin products and services (including but not limited to providing personalized services to You), and we will inform You through such means as website notification, email, telephone or short message.
You understand and agree that the functions and service scenarios we provide You are continuously upgraded through iteration. If we do not state You the Personal Information need to be collected in the above scenarios, we will separately express the content, scope and purpose of information collection to You through page prompts, interactive design and other methods to seek Your consent.
If we stop operating Lanxin products or services, we will stop collecting Your personal information in a timely manner, notify You 30 days in advance of the notice of the stop, and delete or anonymize Your Personal Information held in accordance with applicable laws.
(2) Improvement of our products and services
1. Improvement of user experience. To continuously improve our products, eliminate and reduce the product failures, and provide you with better product functions and services, we will collect abnormal running logs of server and client, patch installation failure logs, attributes of terminal peripherals and abnormal software information of terminal, and the above-mentioned information will be used for troubleshooting, e.g., failure elimination, improving patch installation rate, and enhancing peripheral identification accuracy. However, the information will not involve personal information of you or your employees.
2. Handling of your feedback. In the process of service use, you may propose feedback on the experience problems of Lanxin products and services to help us better understand your experience and demand in using our products or services, and improve our products or services. For this reason, we will record your contact information, feedback or suggestions, so that we can further contact you to give you feedback on our solutions.
With personal information of relevant personnel, you may provide or order services for others through Lanxin service. When the organization user of your enterprise is submitted for Lanxin enterprise organization authentication, in addition to the enterprise documents including enterprise name and business license/organization code certificate of the enterprise organization user, the name and identity information of the administrator and the legal representative are also required. You understand and agree that before you provide us with the aforementioned personal information of the actual relevant personnel, you need to make sure that you have obtained their authorized consent. If the above individual disagrees, we will not be liable for the possible infringement caused by the individual.
(3) Security assurance
In order to improve the security of your use of services provided by us, our affiliates and partners, protect your or other users or personal and property security of the public from infringement, better prevent phishing websites, frauds, network loopholes, computer viruses, network attacks, network intrusion and other security risks, and more accurately identify violations of laws and regulations or relevant agreements and rules of Qi’anxin Technology, we may use or integrate your equipment information, software use information and the information shared by our affiliates and partners with your authorization or according to the law for identity verification, security incident detection and prevention, and take necessary record, audit, analysis and disposal measures in accordance with the law.
(4) Exceptions with authorized consent
According to relevant laws and regulations, it is not necessary to obtain your authorization and consent to collect your user information in the following situations:
1. The information is related to national security and national defense security;
2. The information is related to public safety, public health and major public interests;
3. The information is related to criminal investigation, prosecution, trial and judgment execution;
4. Related information needs to be collected in order to protect the life, property and other major legitimate rights and interests of the information subject or other individuals, but it is difficult to obtain your consent;
5. The collected user information is disclosed by you to the public;
6. The user information is collected from lawfully disclosed information, e.g., lawful news reports and government information disclosure;
7. The information is necessary for contract signing according to your requirements;
8. The information is necessary for maintaining the safe and stable operation of the provided products or services, e.g., finding and disposing the failures of products or services;
9. The information is necessary for legitimate news reporting;
10. The information is necessary for academic research institutions to conduct statistics or academic research based on public interests, and to identify the information contained in the results of academic research or description when these results are disclosed to the public;
11. Other situations stipulated by laws and regulations.
II. How we use Cookies (and other similar tracking technologies)
To provide you with better user experience, when you use Lanxin products or services, we may collect and store data relevant with your visit to Lanxin service by employing various technologies. In this way, when you visit or revisit Lanxin service, we will be able to identify you and provide customized services to you by analyzing your Personal Information. This will include verifying your identity through small data files, so that we will be able to understand your habits or assist you with using the services (for example to help you avoid repeated input of account information or help assess the security of your account). These data files may be Cookie, Flash Cookie or other local storage provided by your browser or relevant applications (collectively, “Cookie”).
Please understand that some of our services can only be realized by using Cookie. If Your browser or add-on service allows, You can modify the acceptance of cookies or reject Lanxin Cookies, but in some cases You may not be able to use some features of Lanxin services that rely on Cookies.
III. How we store user information
The user information we collect and generate in the People's Republic of China will be stored within the territory of the People's Republic of China.
If it is necessary to transmit the relevant user information collected in China to overseas institutions for the purpose of cross-border business, we will abide by the provisions of laws, administrative regulations and relevant regulatory authorities, and make ensure that the user information is adequately protected, such as anonymization and encrypted storage.
We store user information only during such periods as are necessary for the purposes of this policy and within such time limits as are required by laws and regulations.
If we stop the operation of Lanxin, we will stop collecting user information in a timely manner, and inform you of the notice of operation termination in the form of one by one delivery or announcement, and delete or anonymize the user information stored by us.
IV. How we share, transfer and publicly disclose user information
(1) Information sharing
We will not share user information with any company, organization or individual, except for the following situations:
1. With your explicit consent, we will share user information with other parties.
2. We may share user information with others in accordance with laws and regulations, litigation dispute resolution needs, or as required by administrative and judicial authorities according to law.
3. It is necessary to share user information within the scope permitted by laws and regulations in order to protect the interests, property or safety of Lanxin, its affiliates or partners, you or other users or the public.
4. In the case that our affiliates provide services to you or us, we may share user information with them. However, we only share necessary user information, and the processing of your information by the affiliates is subject to this privacy policy. If the affiliates intend to change the processing purpose of your user information, they will ask for your authorization and consent again.
5. Unless expressly authorized and agreed by you, we will not share user information with third-party advertisers, application developers, open platforms or other partners. We may provide these partners with aggregated information, anonymous information or other information unavailable for your identification.
6. For the purposes stated in this privacy policy only, we may share user information (or the SMS or caller ID reported by the user) with our suppliers, service providers, consultants or agents to provide better user services and user experience. These suppliers, service providers, consultants and agents may provide us with technical infrastructure services, analyze the way to use our services, measure the effectiveness of advertising and services, offer customer services and payment services, conduct academic research and investigation, or render legal, financial and technical consulting services.
We will enter into strict data protection agreements with companies, organizations and individuals with which we share user information, requiring them to process user information in accordance with our instructions, this privacy policy and any other relevant confidentiality and security measures.
(2) Information transfer
We will not transfer the user information to any other company, organization or individual, except for the following situations:
1. With the development of our business, we and our affiliates may conduct merger, acquisition, asset transfer or other similar transactions. If the transaction involves the transfer of user information, we will require the companies, organizations and individuals newly holding user information to continue to be bound by this policy, otherwise we will require them to re-obtain your authorization and consent.
2. With your explicit consent, we will transfer the user information that we have obtained to other parties.
(3) Information disclosure
We will only publicly disclose user information under the following circumstances:
1. Your explicit consent has been obtained.
2. We may publicly disclose user information as required by law, legal proceedings, litigation or mandatory requirements of government authorities.
3. It is necessary to disclose user information within the scope permitted by laws and regulations in order to protect the interests, property or safety of Lanxin, its affiliates or partners, you or other users or the public.
4. Other situations stipulated by laws and regulations.
According to the provisions of the law, sharing or transferring de-identified user information under the premise of ensuring that the data receiver cannot recover and re-identify the subject of the information, shall not be regarded as the external sharing, transfer or public disclosure of user information. Please be aware that the storage and processing of such data will not require further notice and consent from you.
V. How we protect user information
We have taken security protection measures in line with industry standards to protect the user information you provide and prevent unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonable and feasible measures to protect your user information.
1. We have released Privacy Policy of Lanxin to achieve the transparency of user information processing, establish user feedback channels, and accept the supervision of the public.
2. We will encrypt, transmit and store the identifiable personal identity information to ensure the confidentiality of the data.
3. We deploy access control mechanism on the server side, adopt the principle of minimum sufficient authorization for staff who may have access to user information, and regularly check the list of visitors and access records.
4. Our server systems for storing user information are all operating systems after security reinforcement. We will audit and monitor the server operations. If the server operating systems with security issues in external announcements are found, we will upgrade the server immediately to ensure the security of all our server systems and applications.
5. We organize regular training on laws and regulations related to privacy protection for our staff to enhance their awareness of privacy protection.
6. In case of any damage to our physical, technical or management protective measures, we will launch the emergency plan in time to prevent the expansion of security incidents, report to the national competent authority in accordance with the requirements of laws and regulations, and timely inform you of the basic information, possible impact, measures taken or measures to be taken in a reasonable and effective way, e.g., push and announcement.
VI. Protection of minors
We attach great importance to the protection of personal information of the minors. According to the relevant laws and regulations, if you are a minor, you shall obtain the written consent of your parents or legal guardian before using Lanxin service. If you are the guardian of the minor, please contact us through the contact information in Section 10 when you have any questions about the personal information of the minor under your custody.
VII. Changes and amendments to the privacy policy
Our privacy policy may change. We will not limit your rights under this privacy policy without your explicit consent.
We will also provide significant notification of major changes to this privacy policy (for example, timely notification in the form of pop-ups when software is modified or upgraded, or when you log in again).
Major changes to this policy include but not limited to:
1. Major changes in our service mode, e.g., the purpose of processing user information, the type of user information processed, and the way of using user information.
2. Major changes in control rights, e.g., changes in owners caused by merger and reorganization.
3. Changes in the main objects of user information sharing, transfer or public disclosure.
4. Significant changes in your rights to participate in user information processing and the way you exercise them;
5. Changes of department responsible for user information processing, contact information and complaint channel.
6. High risk indicated in user information security impact assessment report.
VIII. How to contact us
If you have any questions, comments, suggestions or complaints about our privacy policy and the processing of user information, please contact us by the following means:
Customer service hotline: 4006110220 (8:00—20:00, Monday to Sunday)
Customer service email: service@comisys.net
Our mailing contact information is as follows:
Lanxin Mobile (Beijing) Technology Co., Ltd.
Department: Lanxin Customer Service Center
Address: Floor 6, East 878, No. 24, Jiuxianqiao Middle Road, Chaoyang District, Beijing; Zip code: 100015
IX. Effectiveness of privacy policy
The version of this privacy policy gets online and takes effect as of August 29, 2019.