Privacy Policy

This privacy policy (“Policy”) is intended to provide visitors and users (collectively “you”) of the website www.70mai.com with information relating to how and why SHANGHAI 70MAI DIGITAL TECHNOLOGY CO., LTD. (“70mai”, “we”, “us” or “our”) collect, store, use, and/or share (“process”) your personal data/personal information within its application scope and about your rights in this respect. Please review this Policy before using any services available on the website (“Services”).

70mai places the highest priority and takes the utmost care to protect your personal data/personal information.

Note: 70mai may amend the terms of this Policy, in particular if a new processing is carried out. Please check this page regularly to ensure that you agree with any changes. You will be notified of these modifications, either through a special note on our website or through a notification by email.

1.Why and How do We Collect Your Personal Data

Personal Data that We Collect Directly from You

We may collect personal data directly from you when you use our website and our Services, this is specifically the case when you:

• Register to receive our newsletter or documentation;
• Interact with us directly or through the contact forms.

The categories of personal data that we collect include:

• Registration information: e.g., country/region, email address, password needed to file a registration;
• Identification and contact information: e.g., last name, first name, email address, contact details needed to identify you when you interact with us.

Personal Data that We collect Indirectly

We may indirectly collect certain personal data about you when you access or use our website, specifically:

• when you register with linked accounts;
• through cookies or similar technologies placed on your device.

The categories of personal data that we collect include:

• linked accounts: when you choose, at your own will, to use a third party account (Facebook, Google or Apple) to register and log in to the website, we will indirectly collect, through your authorization, your account name, password and other information that you agree to provide on the third party’s authorized login screen;
• technical information: we may collect information when you access or use our website, such as your IP address or other browsing information (including access time, access pages and the link that enabled you to access our website), through cookies or similar technologies placed on your device. Some cookies are required for the proper functioning of our website and others are used for analytics purposes which help us to provide you with more personalized and customized services and a better digital experience. For more information about cookies and to know how you can edit your preferences, please read our Cookie Policy.

2.How We may Use Your Personal Data and What are the Legal Bases

70mai only utilizes your personal data when there is a legitimate and lawful basis for doing so, this may be because:

• you have provided your consent to us. Please note that for this specific legal basis, you have the right to withdraw your consent at any time (see below the “Your Data Rights” section);
• our use of your personal data is necessary to perform our contract with you;
• our use of your personal data is necessary to meet legal requests from government or law enforcement authority’s conduction of an investigation;
• our use of your personal data is in our legitimate interest as a commercial organization, for example, to operate and improve our Services and to keep you informed about our products and services (including for profiling and targeted advertising) - in these cases we will look after your personal data at all times in a way that is proportionate and respects your privacy rights;
• our use of your personal data is intended to detect, prevent fraud, security, potential deceptive or illegal activities. We may use your personal data to create a secure environment for businesses, individuals, and systems to operate in, while minimizing the risk of fraud and other illegal activities, to maintain trust, prevent financial losses, and promote a fair and transparent market.

If you would like to find out more about the legal basis for which we process personal data, please contact us (details found in the “How to Contact Us” section).

3.Where We may Store Your Personal Data and How Long Will We Retain Your Personal Data

Your personal data are stored on the servers of companies we engage to provide services to us. To the extent that we may need to transfer personal data outside of your jurisdiction, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards.

When you use our Services, we process and keep most personal data we process for as long as you are an active user of our Services. We delete certain personal data we collect about you when we no longer have a business reason to retain it. Additionally, there is some personal data we need to retain even after you close your account to comply with business and legal requirements.

4.Disclosure of Your Personal Data

We may disclose your personal data with other third-party data controllers with your consent (where necessary). The types of third parties your personal data may be disclosed to include: our resellers and other sales and advertising partners, retailers, advertisers, ad agencies, advertising networks and platforms, information service providers, fraud monitoring and prevention providers, and publishers. In some cases, in order to show you more relevant ads, we disclose with social media platforms and other advertising partners, information about actions you take on our websites and apps, such as which pages you visit and which ads you saw.

We may disclose for Fraud Prevention, Safety and Security Purposes.

We may disclose personal data to companies that help us run our business to detect, prevent, or otherwise address fraud, deception, illegal activity, misuse of our Services, and security or technical issues.

We may disclose when you agree to the disclosure;

We may disclose or publish aggregate information that doesn’t specifically identify you, such as statistical information about visitors to our websites.

5.Your Data Rights

Your data rights are important to us. You have several rights under the law of some jurisdictions as following. Raise your requests to excise your rights, you can reach us via email dataprotection@70mai.com.

• Request access to your personal data: you have the right to obtain a copy of the personal data we hold about you and certain information relating to our processing of your personal data;
• Request correction of your personal data: you are entitled to have your personal data corrected if it is inaccurate or incomplete. You can update your personal data at any time by logging into your account and updating your details directly, or by emailing us at dataprotection@70mai.com;
• Request erasure of your personal data: this enables you to request that 70mai delete your personal data, however in some cases we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
• Request restriction of processing of your personal data: you have a right to ask 70mai to suspend the processing of your personal data in certain scenarios, for example, if you would like us to establish the accuracy of the data, or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Where processing is restricted, we are allowed to retain sufficient information about you to ensure that the restriction is respected in future;
• Object to processing of your personal data: you have the right to object to the processing of your personal data where we believe we have a legitimate interest in processing it (as explained above). You also have the right to object to our processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms;
• Request for data portability: in certain legal jurisdictions, you may possess the right to request a copy of your personal data from us, as well as to ask for corrections, deletions, or restrictions on the active processing of your data. Additionally, you may have the right to acquire the personal data you supplied to us for a contract or with your consent in an organized, machine-readable format and request that we transfer this data to another controller. Your jurisdiction’s data privacy laws may grant you additional rights;
• Request information and stop automated decision making and profiling: you have the right to request information where we are carrying out automated decision making when processing your personal data. This form of processing is permitted where it is necessary as part of our contract with you, providing that appropriate safeguards are in place or your explicit consent has been obtained. We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of the above rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it;
• Right to lodge a complaint: if you have any concerns or complaints regarding the way in which we process your personal data, please email us directly at dataprotection@70mai.com;
• Right to lodge a complaint with a supervisory authority.

6.Security of Your Personal Data

We work hard to protect your personal data. We employ administrative, technical, and physical security controls where appropriate, such as employ advanced encryption technology for all users’ sensitive information and store it encrypted; encrypt data transmission channels to ensure the security of data transmission; conduct regular security tests and vulnerability scans, and update the virus database promptly; implement effective server environment access control to prevent external intrusion; configure firewalls; maintain strict operation audit records; periodically perform security baseline checks and promptly repair vulnerabilities according to security benchmark requirements; regularly back up system data to prepare for catastrophic events; develop comprehensive emergency response plans to ensure data security; and periodically provide security training for relevant personnel to raise security awareness.

7.Minors

Our website is not intended for minors and we do not intentionally solicit or collect personal data from individuals under the age of 16. If we are notified or otherwise discover that a minor’s personal data has been improperly collected, we will take all commercially reasonable steps to delete that information.

8.How to Contact Us

We are open to receiving your feedback and will gladly address any inquiries related to your personal data. Feel free to reach out to us at: dataprotection@70mai.com.

Addendum - US Consumer Privacy Act Statement

What does this page cover?

In the United States, certain states have enacted their own privacy legislation. For residents of these states, this page serves as an addendum to our Privacy Policy, detailing your specific privacy rights. It also offers the required disclosures regarding our handling of your personal information and encompasses the following:

• California and Virginia specific disclosures and rights
• What personal information do we sell or share
• How to request opt-outs for sale or sharing of personal information
• Who you can contact with questions or concerns
• What rights do you have regarding your personal information and how you can exercise these

California Residents

If you are a resident of California, we have certain obligations, and you have certain rights with respect to your personal information, including:

• You may request that we disclose to you the following information:
• The categories of personal information we collected about you and the categories of sources from which we collected such personal information;
• The specific pieces of personal information we collected about you;
• The business or commercial purpose for collecting, selling, or sharing (if applicable) personal information about you;
• The categories of personal information about you that we sold or “shared” and the categories of third parties to whom we sold or “shared” such personal information (if applicable); and
• The categories of personal information about you that we otherwise disclosed, and the categories of third parties with whom we disclosed such personal information (if applicable).
• You may request to correct inaccuracies in personal information
• You may request to delete personal information
• You may request data portability
• You may request to opt out from limit use and disclosure of sensitive personal Information
• You may request to opt out from the sale or share of personal information

You may designate an authorized agent to exercise some of your rights; however, in order to help protect the security of your personal information, the authorized agent must follow the same authentication procedures that are required if you exercise your rights without using an agent.

Virginia Residents

If you are a resident of Virginia, we have certain obligations, and you have certain rights with respect to your personal information, including the rights to your personal information that is being processed, correct inaccuracies in personal information, delete personal information, request data portability, opt out from sale or sharing of personal information, opt out from targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

We retain personal information for the duration necessary or allowed, considering the reason(s) it was gathered. Criteria that influence our retention periods include:

• The duration of our ongoing relationship with you and the provision of Services to you (e.g., as long as you hold an account with us or continue using our Services)
• Any legal obligations we must adhere to (e.g., specific laws mandating that we retain records of your subscription for a set time before deletion)
• The advisability of retention in light of our legal standing (e.g., considering statutes of limitations, litigation, or regulatory inquiries)

What personal information do we sell or share

We neither share nor sell your personal information with any third parties. Data collection and sharing are limited to essential personal information needed for our partners to fulfill your requests. When accessing our website via desktop or mobile devices, we may gather and utilize cookies or other identifiers to deliver personalized advertisements for 70mai and third-party products. This can occur through email, on our website, or across other internet sites. Additionally, we monitor your interactions with our website and remember your preferences. The primary method for this data collection is through cookies, which store information directly on the device you are using.

If you would like to exercise one or more of these rights, please review the “What rights do you have regarding your personal information and how you can exercise these” section in this Policy. If you would like to opt out of targeted advertising or the sale of personal information, please see our Do Not Sell or Share My Personal Information for more information on how to exercise this right. For the categories above, 70mai “sells” or “shares” the data solely for the purposes of marketing and promotion.

What rights do you have regarding your personal information and how you can exercise these

Under the law of some jurisdictions, you may have the right to ask us for a copy of your personal information; to correct, delete or restrict (stop any active) processing of your personal information; and to obtain the personal information you provide to us for a contract or with your consent in a structured, machine-readable format, and to ask us to share (port) this information to another controller. You may be entitled to additional rights based on applicable data privacy laws in your jurisdiction.

In addition, you can object to the processing of your personal information in some circumstances (such as where we are using the information for direct marketing).

These rights may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law to keep or which we need to defend claims against us.

When you are asked to provide personal information, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional. For example, to register with 70mai, to create an ID, and to use some 70mai Services, the provision of some information is mandatory: if relevant information is not provided, then we will not be able to administer an 70mai account to you, or provide you with the Services requested.

To exercise any of these rights, you can get in touch with us

You can get in touch with us using the details set out below:

our data protection office：dataprotection@70mai.com.

Additionally, many of our Services allow you to edit your personal information by accessing the “my account” or a similar feature of the Services you are using. Likewise, you can delete information you have stored in our Services by logging in and using the deletion functions that are available.

If you have unresolved concerns, you have the right to report them to your local privacy regulator or data protection authority and, where applicable, you also have the right to lodge a complaint with your jurisdiction data protection commission.