Privacy Policy of Shanghai University of Finance and Economics ("this Agreement") applies only to the products and/or services (collectively "our services") provided by Shanghai University of Finance and Economics ("SUFE" or "we") to you. Please be sure to read this Agreement carefully and completely understand it before using our services, especially the clauses marked in bold. You should read it carefully and confirm your full understanding and agreement before using it. If you do not agree to the content of this Agreement, you may not be able to create an account, the services may not work properly, or the services may not achieve the results we intend. Please do not register, login or use our services. Please pay special attention to the important contents relating to personal sensitive information and your personal information rights and interests which have been highlighted in bold form. If you are a minor under the age of 14, please be accompanied by your parent or other guardian, read carefully and fully understand this Agreement, and obtain the consent of your parent or other guardian before using our services.
Legends
This Agreement applies to all of the services we provide. When you use any of our services, you agree to accept the protections of this Agreement. If this Agreement does not apply to any service we provide, this Agreement will be expressly excluded in an appropriate manner from being applicable to that service.
If, after reading this Agreement, you have any questions about this Agreement or matters related to this Agreement, you may contact us through the feedback channels listed in the section "How to Contact Us" of this Agreement and we will answer your questions as soon as possible.
This Agreement will help you understand:
I Definitions and Interpretation
1. Our services
Refer to various products and/or services provided by SUFE to you, namely, the Center for Optimization Algorithm Platform (hereinafter referred to as the "COAP") and the optimization algorithm services provided by COAP.
2. SUFE
Refers to Shanghai University of Finance and Economics. If you would like to know more about SUFE, you may contact us through the contact information set out in Section 11 of this Agreement.
3. Affiliates
Refer to any party which, directly or indirectly, controls, is controlled by or is under common control with SUFE. "Control" and "controlled" herein shall mean, respectively, the right to direct the management policies of a party whether through voting right, by contract or otherwise.
4. Users
Refer to the visitors who access our service website, register, login and use COAP and our services, and browse or upload data to COAP. More commonly referred to as "you" in this Agreement.
5. Account
Refers to the User account held by you after completing the registration of real information. This account is maintained by you. You shall take legal liability for all the actions conducted under your Account.
6. Personal information
Personal information refers to all kinds of information relating to identified or identifiable natural persons recorded in electronic or other forms, excluding information that has been anonymized. For the avoidance of doubt, personal information includes but not limited to sensitive personal information.
7. Sensitive Personal Information
Sensitive personal information refers to the personal information that is likely to infringe upon the personal dignity of a natural person or endanger the personal or property safety of such person once divulged or illegally used, including information on biological identification, religious belief, specific identity, medical health, financial account number and whereabouts and tracks, as well as the personal information of minors under the age of 14.
8. Processing of Personal Information
The processing of personal information includes the collection, storage, use, processing, transmission, provision, publication and deletion of personal information.
9. Personal Information Processors
Personal information processors refer to the organizations and individuals that independently determine the purposes and methods of processing during the processing of personal information.
10. Personal Information Subject
The subject of personal information refers to the natural person identified or associated by personal information.
11. Automated decision-making
Automatic decision-making refers to the activity of automatically analyzing and evaluating an individual's behavior habits, interests and hobbies or economic, health and credit status through a computer program, and making a decision.
12. De-identification
De-identification is the process by which personal information is processed so that it is impossible to identify specific natural persons without the aid of additional information.
13. Anonymization
Anonymization refers to the process by which personal information is processed so that it is impossible to identify a specific individual and is not recoverable.
14. Equipment
Refers to a device that can be used to access the COAP or use our services, such as a desktop computer, laptop, tablet or smartphone.
15. Information-gathering technique
"Automatic gathering" in this Agreement includes the following methods:
(1) Cookie: A cookie is a small text file that is placed in the terminal (your computer, mobile phone or other smart terminal) by the web server while you are browsing the web, and can be used to improve your experience.
(2) Web beacon: A Web beacon is an electronic image file or other technology that is embedded in a web site or email and can be used to count the number of visitors, to record if and when you view an email or web site, or to use certain Cookies.
(3) Log files: A Log file stores several pieces of data that are automatically collected. Such data includes Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referrer/exit page, operating system, date/time stamp and clickstream data, etc.
(4) ET Tag: An ET Tag is an HTTP protocol header that is behind the scenes between an Internet browser and an Internet server and can be used to track individual users instead of cookies so that we can better understand and improve our services.
(5) JavaScript: JavaScript is a programming language that is used to make Web pages more interactive and dynamic. JavaScript can set cookies, read cookies and delete cookies.
II How We Collect and Use Your Personal Information
1. Personal Information Voluntarily Provided by You in the Process of Providing Products and/or Services
When you access, register, login and use the COAP and our services:
(1) In order to implement our basic business functions, you only need to provide us with the basic necessary personal information corresponding to such functions, except for the special requirements set forth in relevant laws, regulations and administrative documents. If you refuse to provide such information, we will not be able to provide you with the corresponding services. Please note that if you provide personal information other than your own, please ensure that you have obtained the consent of the relevant person.
a) Account Registration/Login and Use
If you choose to use the functions of the COAP, in order to use the complete services provided by us to you, you are required to register for a COAP account. When you register or login an account on the COAP, you are required to provide your account name, email address, name, nickname, industry, position and set up a login password, and activate your email so that we can verify your identity and protect your account from unauthorized access. If you only need to use input, view, search and other functions to access relevant services, you are not required to register for a COAP account and provide the above personal information.
b) Real Name Authentication
When you use the services provided by us, your real name authentication may be required as required by relevant laws and regulations. Real name authentication requires the uploading of real name authentication information. Different real name authentication subject types will require different real name authentication information. Such information includes: name, ID number, company name, company credit code, company registration address, organization information, student ID card information, ID card information, project information, founder information and business plan. The above information will only be continuously stored and used by the COAP during the period when you use the COAP and our services. When you voluntarily deregister your account, we will de-anonymize or delete your personal information as soon as possible as required by applicable laws and regulations.
c) Image, Text Input
When you use the optimization algorithm services provided on the COAP website, we may collect your text information and image information as collection is necessary for the above functions. In the meantime, we will judge your needs after collecting text information and give you the feedback in real time. Please be aware that, when you experience the aforesaid functions of the COAP, the images and text contents you input may contain your personal information or other persons' personal information, but we will not identify individuals based on the contents of the personal information involved, and will only conduct technical analysis by extracting character strings for input. If you refuse to provide the above information, you will not be able to experience the aforesaid complete services.
You understand and agree that the above services may require you to turn on access to your webcam (camera), photo album (gallery) and microphone (voice) in your device in order to collect and use the information involved in these permissions. You may review the status of each of the above permissions in your device settings, and may turn on or off these permissions at any time at your discretion. Please note that, by turning on any permission, you authorize us to collect and use the relevant personal information to provide the services for you. Once you turn off any permission, you revoke the authorization, and we will no longer collect and use the relevant personal information based on the permission, nor will we be able to provide the services for you based on the permission. However, your decision to turn off a permission will not affect previous collection and use of information based on your authorization.
(2) In order to provide you with better platform and services, we may need to collect the following information. If you refuse to provide the following information, it will not affect your normal use of the basic business functions under Section 1.1, but you may not get the user experience brought to you by these extended business functions.
a) Order Generation
When you choose to purchase or use our services, you are required to provide us with a question file and select a solver. Accordingly, our system will generate an order to use or purchase the services. You may be required to fill in your email address. The order will specify the order number, the services you use or purchase, the amount payable (if any) and the method of payment (if applicable). All the above information shall constitute your "Order Information". We will provide you with order inquiry, payment settlement, delivery completion, customer service consulting and after-sales service through orders. You may make inquiry through email or the console in the COAP.
b) Payment
If you choose to purchase our services, after placing an order, you may choose to make bank remittance to SUFE to pay the order. You shall at least provide us with the name of the remitting bank, account number, account name, amount and time of the remitting bank for checking the transaction amount with the bank remittance record, so that the bank will confirm your payment instruction and complete the payment. You may also use third-party payment services provided by Wechat Pay and Alipay Pay. The payment function itself does not collect your personal information. However, we need to share your order number and transaction amount information with these payment institutions so that they can confirm your payment instruction and complete the payment.
c) Event Participation and Service Improvement
When you make use of our customer service or participate in any activities on the COAP, we will collect information that you fill in on a voluntary basis. For example, when you participate in any online activities on the COAP, the questionnaires you fill in may contain your name, telephone number, email address and home address information. Moreover, when you register, log in or use the COAP, you may enter the account information page of the COAP and voluntarily choose to fill in your nickname, gender, birthday and address information. We may use the above information to provide you with feedback on your activities or conduct user and market research and analysis (for example, to determine the general characteristics of your users), so as to enhance and improve the design of our products and provide you with personalized recommendations and better service experience. However, if you do not provide such personal information, your normal use of all basic functions and services of the COAP will not be affected.
2. Personal Information Proactively Collected by Us in the Course of Providing Products and/or Services to You
In compliance with laws and regulations, in order to ensure the safety of your account and better provide you with services, when you visit, register, log in or use the COAP or use our services, the system may automatically collect certain information through cookies or other methods and keep it as system jurnals. The purpose of collecting such information is to improve and optimize product experience, ensure the stability of services and network security through data statistics. Such information includes your usage details when you use the COAP, including your device name/operating system name, product or service usage history, search query, page address visited, login IP, browser type, network status, operator, language used, date and time of visit, system activity, website information that directs you to browse to our platform and webpage history that you visit.
3. Instructions on Data Processing
(1) Based on the information provided by you or actively collected by us, we may make automated decisions (build a portrait) based on a combination of one or more of the above information (for example, device number, mobile application list, system jurnals) to provide you with page display that is better tailored to your needs, recommend personalized content that may be of interest to you, recommend commercial information and marketing advertisements from us or third parties. You may limit the automated decisions in accordance with "Limiting Automated Decisions" subsection in Section 7 of this Agreement. We may also call you, send you marketing messages or emails by telephone, text message, email or other means, to the mobile number or email address reserved in your account information. If you decline to receive text message or email messages (including marketing messages and emails), you may unsubscribe from the subscription through the unsubscribe methods provided in the text message or email. We may also share device information with our COAP affiliates or entrusted partners who may combine this information with other information legally available to them to assist them in increasing effective advertising reach, without identifying you personal indentity, in order to better provide you with our or third parties' commercial information and marketing advertisements. If you decline to receive the aforesaid information, you may give us feedback through the contact information described in Section 11 of this Agreement.
(2) We use the information we collect to ensure our business operation and that of our affiliates and partners, for example, to evaluate, maintain and improve the performance of products and services. In case of system failure, we may record and analyze the information generated when the system failure occurs, in order to optimize related services on our COAP. In order to iterate and develop new products and services, we may statistically analyze the information we collect to assist in decision-making, but the results of the data analysis do not contain any personally identifiable information about you.
(3) Subject to applicable laws and regulations, we may technically process your personal information, making it impossible to accurately identify you based on the information, and anonymize or de-identify the processed information for academic research or statistical analysis (including using anonymized or de-identified textual information or image information to train relevant solver model algorithms) to better improve the functionality of our products and services.
III How we use Cookies and similar technologies
1. Cookie
To ensure the proper functioning of our website, we collect and use your information by storing small data files called cookies on your computer or mobile device. We use our own cookies in order to provide you with a more personalized user experience and services, and for the following purposes:
(1) Remembering who you are. For example, cookies help us identify you as a registered user, or store information you provide us about your preferences or other information;
(2) Analyzing your use of our services. For example, we can use cookies to understand what you do with our services, or which pages or services are most popular with you;
2. Website Beacons and Pixel Tags
In addition to cookies, we may also use similar technologies on our website, such as website beacons and pixel tags. For example, an email we send you may contain a click-through URL that links to content on our website. If you click on that link, we track that click to help us understand your product or service preferences and improve customer service. Website beacons are usually transparent images embedded in websites or emails. With the help of pixel tags in emails, we can see if the email has been opened. If you do not wish to have your activities tracked in this way, you can unsubscribe at any time from our mailing list.
3. Do Not Track
Many web browsers have a Do Not Track feature, which allows you to place a Do Not Track request to a website. Currently, major Internet standards organizations do not have policies in place on how websites should respond to such requests. However, if your browser has Do Not Track enabled, then all of our websites will respect your choice.
Please note that cookies and similar technologies may be placed by advertisers or other third party providers on our products and services. These cookies and similar technologies may collect non- personally identifiable information about you for the purpose of analyzing how users use the services, directing advertisements to you that you may be interested in, or evaluating the performance of advertising services. The collection and use of this information by such third party cookies and similar technologies are not governed by this Agreement, but rather by the privacy policies of the users concerned. We are not responsible for third party cookies and similar technologies.
You can set up settings in your browser to refuse or manage cookies and similar technologies. Specifically, you may set up settings as described in Section 7 of this Agreement. Please note, however, that if cookies and similar technologies are disabled, you may not enjoy the best experiences with the services and certain services may not work properly.
IV How We Entrust the Processing, Sharing, Transfer and Public Disclosure Your Personal Information
1. Entrustment
In order to provide you with better products and services, we may entrust third parties (including companies, organizations and individuals) to process certain of your personal information. Any third party entrusted by us to process your personal information may enter into a strict data processing agreement with it, which shall expressly stipulate the purpose, duration and manner of the entrusted processing, type of personal information, protection measures and the rights and obligations of both parties. The personal information processing activities of the third party shall be supervised, and the third party is requested to process your personal information only in accordance with our requirements, the provisions of this Agreement and any other relevant confidentiality and security measures, and may not process personal information beyond the agreed purpose and manner. If you refuse to allow any third party to collect personal information necessary for the provision of our services, you may not be entitled to the services provided by such third party in the course of your use of the products and/or services on the COAP.
For example, when you use the products and/or services provided on the COAP, your real-name authentication is required under relevant laws and regulations. We will verify this information through a credit reference company recognised by the national authority in charge of credit rating. If you refuse to allow any third party to collect personal information necessary for the provision of our services, you may not be entitled to the services related to real-name authentication provided by the supplier in the course of your use of the products and/or services on the COAP.
2. Sharing
We will not share your personal information with third parties (including companies, organizations and individuals), except for the following circumstances:
(1) Sharing with Express Consent: With your express consent, we may share your personal information with other parties.
(2) Sharing under Statutory Circumstances: We may share your personal information with external parties in accordance with the provisions of laws and regulations, as necessary to resolve litigation or disputes, or as required by administrative or judicial authorities in accordance with the law.
(3) Sharing with Affiliates: Your information may be shared among affiliates of SUFE for the purpose of linking with our other products or services to provide better services to you, or to protect the personal or property safety of affiliates of SUFE or other users or the public from harm. We will share your personal information among affiliates of SUFE only for specific and lawful purposes within the scope of the stated purposes of this Agreement, and only the information necessary for the provision of services. For example, in order to avoid duplicate registration, we need to check the global uniqueness of the account to be registered. However, for the information shared with affiliates, we will require affiliates to protect your information at least as protective as stated in this Agreement, and to strictly comply with relevant laws, regulations and regulatory requirements. If affiliates want to change the purpose of handling your personal information, they will need to obtain your authorization again.
(4) Sharing with Authorized Partners: Certain of our services will be provided jointly by us and our authorized partners, solely for the purposes stated in this Agreement. We may share certain of your personal information with our partners to provide better customer service and user experience. We will only share your personal information for legal, proper, necessary, specific and lawful purposes, and only the personal information necessary for the provision of services. Our partners are not authorized to use shared personal information for any other purpose. Currently, our authorized partners include the following types:
a) Authorized Partners for Advertising and Analytics Services. We will not share your personally identifiable information (meaning any information that identifies you, such as your name or email address, that allows you to be contacted or identified) with our advertising and analytics partners unless you consent. We will provide these partners with information about advertising and marketing services and their coverage and effectiveness, such as information about your devices. Such partners may combine this information with other data legally available to them to help increase effective reach without personally identifying you.
b) Suppliers, Service Providers and Other Partners. We send information to our suppliers, service providers and other partners that support our business, such as providing technology infrastructure services, analyzing how our services are used, measuring the effectiveness of advertising and services, providing customer service or conducting academic research.
We will sign strict confidentiality agreements with the companies, organizations and individuals with whom we share personal information, requiring them to process personal information in accordance with our explanatory notes, this Agreement and any other relevant confidentiality and security measures, and requiring them to process personal information in a manner that does not violate PRC laws and regulations, national standards and other regulatory documents concerning personal information protection and data security. In principle, the companies, organizations and individuals with whom we share personal information are not authorized to use the personal information we share for any purpose other than this Agreement.
3. Transfer
We will not transfer your personal information to any third party (including companies, organizations and individuals), except for the following circumstances:
(1) Transfer with Express Consent: We may transfer your personal information to other parties with your express consent;
(2) Provide it where necessary in accordance with applicable laws, regulations, legal proceedings, mandatory administrative or judicial requirements;
(3) In the event of merger, acquisition or liquidation of any service provider of this product, or any other circumstances involving merger, acquisition or liquidation. In the event of a transfer of personal information, we will inform you of the name and contact information of the recipient(s) of your personal information and require that the new recipient(s) of your personal information continue to be bound by this Agreement; If a recipient(s) changes the original purpose or method of processing your personal information, we will require the recipient(s) to seek your consent again from you.
4. Public Disclosure
We will only publicly disclose your personal information under the following circumstances:
(1) We may publicly disclose your personal information with your sole consent or based on your voluntary choice;
(2) We may publicly disclose your personal information as required by law, legal proceedings, litigation or mandatory requirements of a government authority;
(3) If we determine that you have violated any law, regulation or material breached the rules of this Agreement, or to protect the life or property of users of this product or its affiliates or the public at large, we may disclose personal information about you, including the violation(s) and any actions we have taken against you for this product, in accordance with any law, regulation or the rules of this product.
5. Exceptions to Prior Authorized Consent for Processing, Sharing, Transfer or Disclosure of Personal Information on Behalf of Others
Your prior authorized consent is not required for the sharing, transfer or public disclosure of your personal information in any of the following circumstances:
(1) Is in connection with our performance of any of our obligations under any law or regulation;
(2) Is in connection with national security and defense security;
(3) Is in connection with public security, public health or vital public interest;
(4) Is in connection with criminal investigation, prosecution, trial and judgment execution;
(5) Is for the purpose of protecting your or other individuals' material legitimate interests such as life and property and it is difficult to obtain your consent;
(6) Is personal information disclosed to the public by you; and
(7) Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels.
Please be aware that, in accordance with the law, the sharing or transfer of personal information with de-identification information to the extent that the data receiver is unable to recover and re-identify the subject of personal information does not fall under the scope of external sharing, transfer or public disclosure of personal information, and such data shall be stored and processed without notice to you or consent from you.
V How We Protect Your Personal Information
1. We attach great importance to users' privacy and protection of personal information, and take reasonable measures to protect users' personal information. Except as required by laws and regulations or otherwise provided for in this Agreement, SUFE will employ various security technologies and procedures to establish a sound management system to protect your personal information from unauthorized access, use or disclosure. Without users' consent, we will not disclose or disclose users' personal information to any third party and will adopt professional encrypted storage and transmission methods to protect the security of users' personal information.
2. You understand and agree that, without disclosing the private information of individual users, SUFE has the right to conduct technical analysis of the entire user database. Only the user data that has been anonymized after analysis and processing will be used commercially.
3. Data Security Measures
(1) The COAP will adopt security measures in line with industry standards, including the establishment of reasonable systems, regulations and security technologies to prevent your personal information from unauthorized access, modification and data damage or loss.
(2) We have obtained the ISO 27001 and ISO9001 level certifications for the cyber security protection provided by the Ministry of Public Security.
(3) We will take all reasonable and practical steps to ensure that we do not collect irrelevant personal information. We will retain your personal information only for the period necessary to achieve the purposes stated in this Agreement, unless the retention period needs to be extended or as permitted by law.
(4) The Internet is not an absolutely secure environment, and emails, instant messaging and other means of communicating with other users are not encrypted. We strongly recommend that you do not send personal information by such means. Please use complex passwords to help us keep your account secure.
(5) The Internet environment is not 100% secure. The COAP will endeavor to ensure or guarantee the security of any information that you send to the COAP. If the physical, technical or management protection facilities of the COAP are destroyed, which causes the information to be illegally authorized access, publicly disclosed, tampered with or destroyed, and your legal rights and interests are damaged, we will bear the corresponding legal liabilities.
(6) After the occurrence of a personal information security incident, SUFE will, in accordance with the requirements of laws and regulations, promptly inform you of the reasons for the security incident, the potential damages, the types of personal information involved, the measures that SUFE has taken or will take, the suggestions for you to prevent and reduce the risks on your own and the measures that can be taken, etc. SUFE will, in a timely manner, inform you of the relevant information of the incident by email, text message, phone call, delivery of notices, etc. If it is difficult to inform the personal information subjects one by one, we will take reasonable and effective methods to make public announcements. In the meantime, SUFE will, in accordance with the requirements of regulatory authorities, actively report the handling of personal information security incidents. Please be aware that, in accordance with the provisions of applicable laws and regulations, SUFE may not inform you if the measures may be effectively prevented from being divulged, tampered with or lost of your personal information.
VI How We Store Your Personal Information
The products and/or services are provided only to the territory of mainland China (for the purpose of this Agreement only, excluding the Hong Kong Special Administrative Region, the Macau Special Administrative Region and Taiwan). In principle, the personal information that we collect in the territory of the People's Republic of China is stored in the territory of the People's Republic of China and will not be transmitted across borders.
1. Places Where Information Is Stored
SUFE complies with the provisions of laws and regulations. The information and data collected about you will be kept on the servers of SUFE in the mainland of the People's Republic of China. However, the following circumstances are excluded:
(1) Expressly provided by laws and regulations;
(2) With your explicit authorization; and
(3) You conduct cross-border transactions on your own initiatives through the Internet.
2. Duration of Storage
In general, we will retain your personal information for the minimum period of time necessary to achieve the purposes set out in this Agreement during your use of the products and/or services on the COAP, unless otherwise provided for by applicable laws and regulations or national regulatory documents. In the event that the above period of time expires or you voluntarily request to delete your personal information or cancel your account, we will delete your personal information as soon as practicable in accordance with the requirements of applicable laws and regulations, unless applicable laws and regulations or national regulatory documents require a longer period of retention of such information. However, in the following circumstances, SUFE may change the storage period of personal information due to compliance with the requirements of laws:
(1) In order to comply with the applicable laws and regulations and other relevant provisions;
(2) In order to comply with the provisions of court judgments, orders or other legal proceedings;
(3) In order to comply with the requirements of the relevant governmental authorities or statutorily authorized organizations;
(4) SUFE has reasons to believe that it needs to comply with the applicable laws and regulations and other relevant provisions; and
(5) The purposes reasonably necessary for the implementation of the relevant service agreements or this Agreement, the maintenance of social and public interests, and the purposes reasonably required for the protection of the personal and property safety or other legitimate rights and interests of SUFE's customers, SUFE, other users or employees.
After you terminate your use of the COAP, SUFE will cease the collection and use of your information, unless otherwise required by laws, regulations or regulatory authorities.
When the relevant services of the COAP cease to operate, SUFE will notify you by sending notices and announcements, and delete your personal information retained in the servers within a reasonable period of time.
VII How You Exercise Your Right To Manage Your Personal Information
In accordance with the relevant laws, regulations and standards of China, you shall have certain rights in the personal information processing activities, such as:
(1) You shall have the right to know and to make decisions on the processing of your personal information, and shall have the right to restrict or refuse the processing of your personal information by others, unless otherwise provided by laws and administrative regulations;
(2) You shall have the right to access and copy your personal information from personal information processors, unless otherwise provided by laws;
(3) You shall have the right to request that your personal information be transferred to the personal information processors designated by you;
(4) If you find that your personal information is inaccurate or incomplete, you shall have the right to request the personal information processors to make correction or supplement;
(5) You shall have the right to request the deletion of your personal information;
(6) You shall have the right to request the personal information processors to explain their personal information processing rules.
When you use the COAP and the services of SUFE, you may refer to the following steps for relevant operations:
1. Access to your personal information
You may check your nickname, email address, mobile phone number, login password and other basic information by logging in to the registered account and clicking on "personal settings" to enter into the personal settings interface.
The COAP is a business conducted through website, the specific operation of which may vary from version to version. If you fail to access such personal information through the aforesaid operation, you may contact our customer service in accordance with the methods mentioned in Section 11 hereof and we will process your request within 20 working days.
2. Correction/supplement of your personal information
You may correct/supplement your gender, birthday, domicile, email address, mobile phone number and other basic information other than the login account name by logging in to the registered account and clicking on "personal settings" to enter into the personal settings interface.
The specific operation of the COAP may vary slightly from version to version. If you find that there is an error in the personal information we have processed about you, you shall have the right to request us to make correction. If you fail to correct such personal information through the aforesaid operation, you may contact our customer service in accordance with the methods mentioned in Section 11 hereof and we will process your request within 20 working days.
3. Deletion of your personal information
If you have completed real-name authentication as required by us, you may delete the real-name authenticated information in accordance with the following steps:
After offline verification and notification of the risks, we will process the deletion process for you. You shall also have the right to request the deletion of other personal information other than the real-name authenticated information. You may contact our customer service in accordance with the methods mentioned in Section 11 hereof and we will process your request within 20 working days.
If we decide to respond to your deletion request, we will at the same time notify the entity from whom we obtained your personal information and request them to promptly delete it, unless otherwise required by law or regulation or unless such entity has sole authorization from you.
4. Obtain a copy of your personal information
You shall have the right to obtain a copy of your personal information. You may contact our customer service in accordance with the methods mentioned in Section 11 hereof and we will process your request within 20 working days.
5. Transfer of your personal information
You shall have the right to request that your personal information be transferred to the personal information processor designated by you. If the requests comply with the national cyberspace administration, we will provide you with the means of transfer. You may contact our customer service in accordance with the methods mentioned in Section 11 hereof and we will process your request within 20 working days.
6. Changing the scope of your consent or revoking your consent
You may change the scope of your authorization to us to continue to collect personal information or revoke your authorization by deregistering your account. You may do so by: logging on to the registered account and clicking on "personal settings", and submitting an application for account deregistration. However, account deregistration will not affect any previous processing of personal information based on your consent.
7. Deregistration of account
You may deregister your account by logging on to your registered account and clicking on "personal settings" to submit an account deregistration application. After verification and informing of the risks associated with account deregistration, we will process the deregistration for you. Account deregistration will result in the cessation of all services under such account.
8. Limit automated decision making
You may refer to the following steps:
Open the website for settings and find the privacy and security settings page. Turn off the setting that allows the website to save and read cookies. Please note that the specific way to turn off this setting depends on the type of browser you choose. In the case of Google Chrome, you may refer to the following steps:
(1) Go to the settings page that comes with the browser;
(2) Click on advanced to expand the settings list;
(3) Click the "Content Settings" in the "Privacy Settings and Security" column;
(4) Click on Cookie to go to the Cookie setting page;
(5) Turn off "Allow the website to save and read cookie data (recommended)".
If you do not wish to receive push messages or emails (including marketing messages and emails), you may do so through the unsubscribe method provided in the message or email.
In addition to the above, you may contact our customer service in accordance with the methods mentioned in Section 11 hereof and we will process your request within 20 working days.
9. Respond to your request
We will take proper technical means to ensure that you may access, supplement, correct and delete your personal information or apply to us for supplement, correction, deletion, copy and transfer of relevant information through the feedback or complaint channels of the products and/or services published on the COAP. We will process your application in accordance with the procedures after receiving it. For security reasons, we may require you to verify your identity in accordance with the procedures, and we will need you to provide your account number (email address) and activate your email. We will process your request only after successful verification. We will reply to you within 20 working days. In principle, we will charge no fee for your reasonable requests. However, in the event of repeated requests or requests that exceed the reasonable limit, we may charge a certain amount of costs as the case may be. We may refuse requests that are unreasonably repetitive, require excessive technology efforts (for example, require the development of new systems or fundamental changes to existing practices), risk the legitimate rights and interests of others, or are so impractical (for example, involve information stored on backup tapes).
If you are unable to access, supplement, correct, delete, copy and transfer your personal information, or change the scope of your consent or revoke your consent, deregister your account, limit automated decision making and turn off targeted push, or you need to access, supplement, correct, delete, copy and transfer other personal information generated through your use of the COAP, or you believe that we have violated any laws or regulations or agreeements with you on the collection or use of personal information, you may contact us through the official feedback channels we publish for relevant products or services.
Please be aware that we will not be able to respond to your request in the following circumstances:
(1) It relates to our performance of obligations under laws or regulations;
(2) It is directly related to national security and defense security;
(3) It is directly related to public security, public health or vital public interest;
(4) It is directly related to criminal investigation, prosecution, trial and enforcement of judgments;
(5) We have sufficient evidence to prove that you have acted in bad faith or abused your rights;
(6) It is for the purpose of your or other individuals' significant legitimate interests such as life, property, etc., but it is difficult to obtain your consent;
(7) The response to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
(8) It involves trade secrets.
VIII How We Protect Minors' Personal Information
1. We attach great importance to the protection of minors' personal information. We will protect minors' personal information in accordance with relevant national laws and regulations.
2. We will treat any person under the age of 18 as a minor. In accordance with relevant laws and regulations, if you are a minor aged 14 or above, we will obtain consent from you or your legal guardian before we collect your personal information, and if you, your parent or other legal guardian request us to correct or delete a minor's personal information, we will promptly take measures to correct or delete such information, unless otherwise provided by laws or administrative regulations.
3. If you are a minor under the age of 14 (hereinafter referred to as "child"), we will obtain the consent of your parent or other legal guardian before we collect your personal information.
4. When processing children's personal information, we will take the following measures to safeguard them: for children's personal information collected, we will, in addition to complying with the provisions on users' personal information stipulated in this Agreement, store, use and disclose children's personal information under the principles of due necessity, informed consent, clear purpose, security assurance and legal use, and strictly comply with the requirements of the Provisions on Online Protection of Children's Personal Information and other laws and regulations. The time limit for collection and use of children's personal information shall not exceed the time limit necessary for collection and use, and we will delete children's personal information after expiration.
5. If you are the parent or guardian of a minor, if you have any questions, comments, suggestions, complaints or reporting needs relating to the matters described in this Agreement, please contact us in the ways described in Section 11.
IX How Your Personal Information is Transmitted Globally
In principle, the personal information we collect within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China and will not be transmitted across borders. If it is necessary to provide your personal information overseas due to business or other needs, we will notify you of the name and contact information of the overseas recipient, the purpose and method of processing, the type of personal information and the methods and procedures for you to exercise the rights provided for herein against the overseas recipient. We will not transmit or allow your personal information to be accessed to the offshore jurisdictions of the country/region where you use products and/or services, unless we have obtained your separate consent and met the conditions for cross-border provision as provided for in laws and regulations.
Please be aware that such jurisdictions may have different laws and regulations relating to the protection of personal information, and we will comply with the requirements of such laws and regulations in such jurisdiction to ensure that your personal information is adequately protected. If such jurisdictions do not have laws and regulations relating to the protection of personal information, we will endeavor to ensure that your personal information receives adequate and equivalent protection within the territory of the People's Republic of China.
X How We Update This Agreement
1. To provide you with better services, the products and/or services on the COAP will be updated and changed from time to time. We will amend this Agreement from time to time and such amendments will constitute a part of this Agreement. However, we will not reduce your rights under this Agreement without your explicit consent. Meanwhile, the COAP will archive the old version of this Agreement for your reference.
2. We will notify you of the changes by giving you a prominent prompt on the page or sending you an email or other means before the changes become effective. The updated privacy policy will come into force after you explicitly consent to the changes (for example, by clicking "Agree" on your affirmative action).
3. In case of material changes, the COAP will provide more prominent notice, including a pop-up notice. If you disagree with this Agreement, or have objections to the amendments to or updates of this Agreement, you may choose to stop using the products and/or services on the COAP or deregister of your account on the COAP. However, please be aware that any acts and activities before your account deregistration or before you stop using the Service shall still be governed by this Agreement.
4. Material changes referred to in this Agreement include but are not limited to:
(1) A material change occurs to the service model of the COAP. Such as the purpose that personal information to be processed, the type and the way of using personal information processed, etc.;
(2) A material change occurs to the COAP in terms of control. For example, change in owners due to merger, acquisition and reorganization;
(3) A change in the main party to whom personal information is shared, transferred or publicly disclosed;
(4) A material change occurs to your rights and the methods of exercising them in connection with your participation in personal information processing;
(5) A change occurs to the department responsible for personal information security, contact information and complaint channel on the COAP;
(6) A high risk is indicated in the personal information security impact assessment report;
(7) A change is made in response to national policies or legal regulations’ promulgation or implementation.
XI How to Contact Us
If you have any questions or suggestions about this Agreement during your use of the COAP, please contact us through the following contact information:
Email: coap@sufe.edu.cn
Address: No. 777 Guoding Road, Shanghai
Postal code: 200433
To ensure our efficient handling of your question and timely feedback to you, you are required to submit your identity certificate, valid contact information and written request and other relevant evidence. We will process your request after verifying your identity. In general, we will reply within 20 working days. If you are not satisfied with our reply, especially if you think our behavior of handling personal information damages your personal information, and we cannot provide a satisfactory reply after your feedback to us and refuse to make any improvement, you may file a complaint and report to the relevant regulatory authority.
XII Miscellaneous
Any dispute arising from or in connection with this Agreement shall be resolved by the parties through friendly consultation; failing which, you hereby agree to initiate legal proceedings in the people's court of the place where SUFE is located.
To the extent not contrary to the applicable laws and regulations, this Agreement shall be interpreted by SUFE.
If any provision of this Agreement is ruled or judged to be invalid by any court of competent jurisdiction, such provision will be excluded from this Agreement, but such invalidity will not affect the validity of the remaining provisions of this Agreement. The remaining provisions of this Agreement shall continue to be performed.