Privacy policy

Release Date: 2021 6th of Dec.

Effective date: 2021 6th of Dec.

Introduction

SHOPASTRO product and/or service platform (hereinafter referred to as “SHOPASTRO” or “Platform”) is owned and operated by ShopAstro (Hangzhou) Network Technology Co., Ltd. (registered address: Room 1701 Times Future City Building 5, Cangqian Street, Yuhang District, Hangzhou City, Zhejiang Province) and its affiliates (hereinafter collectively referred to as "we"), providing online shops to seller users (hereinafter referred to as "users", "you" or "sellers") through SHOPASTRO website www.shopastro.com A SaaS platform with complete solutions for site building, traffic, payment and logistics. 

When you use our platform, we may collect and use relevant information about you (including employees and/or those who operate business on your behalf) and the processing personal information of your end users (hereinafter collectively referred to as "personal information subjects") entrusted by you. We are well aware of the importance of personal information to the subject of personal information. We have formulated the "SHOPASTRO Privacy Policy" (hereinafter referred to as the "Policy") in accordance with applicable laws and regulations, and are committed to protecting the personal information security of you and/or your end users.

We hope to use this policy to explain to the subject of personal information how SHOPASTRO collects, uses, stores, share, transfer, and publicly discloses the purpose, method, scope and information security protection measures of personal information in the process of providing products and/or services, and enable personal information subjects to realize the rights and methods to manage their personal information. Please read this policy in conjunction with the "SHOPASTRO User Agreement". The following are our special tips, please pay attention:

1. SHOPASTRO mainly provides services for corporate customers, so this policy is only applicable to SHOPASTRO's direct processing of personal information of corporate customers' employees and authorized operators. In addition, if our corporate customers embed our services in their products (such as our website building services, etc.), entrusted by the corporate customers, they need to process the end user’s personal information in the process of providing products to the end user, we acting only as a personal information processor, processing the personal information of its end users in accordance with agreements reached with corporate customers. As the personal information controller, corporate customers assume all responsibilities to their end users and are obliged to disclose to end users how to handle and protect the personal information of end users. You should display the specific content of the privacy policy to your end users and provide them with consultation and response to rights requests.

2. For all key content, we use the " bold " or " bold and underline " writing method for prompting. For personal sensitive information, we use the " bold italic " writing method to make special reminders, and we hope you will pay special attention to it when you read it. Before you provide us with any of your personal sensitive information , you have carefully considered and hereby confirm that such provision is appropriate. You hereby agree that your personal sensitive information can be processed in accordance with the purposes and methods described in this policy.

3. SHOPASTRO only provides services to users who are 18 or older. For minors under the age of 18, we do not collect and will not provide any products and/or services of this platform to them. Before using our products and/or services, please confirm that users have met the age requirements, and carefully read and understand the detailed information in this policy. We will not knowingly collect the personal information of minors under the age of 18. If you find that we have unintentionally collected personal information of minors, please notify us immediately and we will try to delete the relevant data as soon as possible.

4. The ways we provide you with the realization of your personal information rights include, but are not limited to, access or correction, deletion of your personal information, account cancellation, withdrawal of consent, and timely response, etc., to ensure that you achieve control over your personal information.

5. Before using this platform, please be sure to read and thoroughly understand this policy, and use the relevant products and/or services of this platform after confirming your full understanding and consent. We recommend that when you use the products and/or services of this platform, you have obtained legal authorization and made wise decisions about the relevant personal information subject information you provided. If you disagree with any content of this policy, you should stop using SHOPASTRO immediately.

6. In order to facilitate the reading and understanding of relevant personal information subjects, we use sentences that are as simple and understandable as possible and define the following key terms. Please refer to the "Appendix: Keyword Definitions " of this policy.

This policy will help you understand the following:

1. How we collect and use personal information of personal information subjects

2. How do we use cookies and other similar tracking technologies

3. How do we entrust the processing, sharing, transfer, and public disclosure of personal information subjects' information

4. How to enable you to have the power to manage personal information

5. How to save and protect personal information

6. How to protect the personal information of minors

7. How to update this policy

8. Jurisdiction and application of law

9. How to contact us

10. Keyword definition

1. How to collect and use personal information of personal information subjects

In accordance with the principles of lawfulness, fairness and necessity, in order to realize the functions described in this policy, we collect and use the information that you proactively provide during the use of this platform, the information generated by your use of this platform, and the information we obtain from third parties. Personal information of relevant personal information subjects. Regardless of the above-mentioned methods to collect and use the personal information of the relevant personal information subject, we will only proceed with your authorization. Please ensure that you have obtained the consent of your end users, unless under certain circumstances, based on legal obligations or may need to protect your or other people's important interests, collect personal information from relevant personal information subjects.

Please understand that due to changes in business strategies, the functions of the platform's products and/or services may also undergo changes and developments. If we want to use the personal information of the relevant personal information subject for other purposes not specified in this policy, or collect and use the personal information of the relevant personal information subject for other specific purposes , we will inform you in a reasonable manner, and Obtain your consent again before collection and use.

(1) In the process of providing you with products and/or services, you actively provide personal information

  1. Register/Login Account

    In order to use the platform, you first need to register a SHOPASTRO account to become our user. Based on this, you need to provide us with the email address required to register your account, the mobile phone number in mainland China, the login password and the verification code we sent to you to verify your identity.

    After completing the registration, you can choose to log in via mobile phone number + verification code or email + login password, and then browse and use SHOPASTRO as a registered user .

  2. Create a trial shop

    In the process of creating a trial store, if you also want other operators to use their mailbox to log in to the store for store management, you need to provide the e-mail address of the store operator. Please ensure that you have obtained the consent of other persons when providing their personal information.

  3. Customer Management

    After creating a store, you can import registered/ordered customer information for store operation and customer management. Please ensure that the personal information of other persons imported by you has obtained the consent to use their personal information in this way at the time of collection.

  4. Paid features

    When you use SHOPASTRO's payment function, we will collect your payment records so that you can check the transaction records that have occurred on the platform, while doing our best to protect the safety of your property and virtual property. The above information is sensitive personal information , please do not provide it to a third party arbitrarily. The collection of the above information is necessary to realize the relevant functions, otherwise the transaction will not be completed.

  5. Upload/publish content

    We will collect content information that you upload or publish on this platform, including text, shared photos, audio, video, and the date, time and location of such information. When you use the above functions, we will ask you for authorization to use the camera, photo album, microphone and location permissions in your terminal device. You can choose whether to provide us with such authorization. If you refuse, you will not be able to use the relevant functions, but it will not affect your use of other functions of SHOPASTRO.

  6. Advertising agency investment

    In order to help you better increase store traffic and achieve customer growth, we will provide advertising agency services, and place your store/product/service advertisements on relevant advertising platforms in your name. Under this function, we may transmit your relevant information to the advertising platform and/or use the pictures, text, videos and other materials in the store page provided by you. Please make sure that the relevant materials do not contain your or user's personal information . If relevant personal information is included, please ensure that you have obtained the consent of the subject of personal information. If you are not sure whether the material contains personal information or cannot obtain authorization, please do not use this function, but it will not affect your use of other functions of SHOPASTRO.

  7. Product recommendation

    When you need to recommend products on the product detail page, in order to achieve a more accurate recommendation effect, we will collect your end user browsing data and behavioral data . When choosing this service, please ensure that you have informed the end users of the collection and use of relevant information and obtained their consent. If you are unable to ensure that your end user has agreed to the collection of the above-mentioned information, please do not use this function, but it will not affect your use of other functions of SHOPASTRO.

  8. Add swatches

    When you use the add swatch function (including swatch management, swatch creation/editing, custom product swatches, and color spot appearance configuration), we will collect and use your store data (including seller ID and store ID) to Correspond the operation of your added color palette to your shop. If you refuse to provide such information, please do not use this function, but it will not affect your use of other functions of SHOPASTRO.

  9. Add shopping cart

    When your end user uses the "add shopping cart" function, in order to make the operation correspond to your store, we will collect and use your store ID to complete the transaction between you and your end user. If you refuse to provide such information, please do not use this feature. We remind you that the effect of your website construction will be affected, but it will not affect your use of other functions of SHOPASTRO.

  10. Credit card payment

     When you or your end user uses a credit or debit card to make a payment, we will collect and use card-related information of you or your end user to complete the payment action of you or your end user. The above information is sensitive personal information , please do not provide it to a third party arbitrarily. The collection of the above information is necessary to realize the relevant functions, otherwise the transaction will not be completed. If you refuse to provide such information, please do not use this feature. We remind you that the effect of your website construction will be affected, but it will not affect your use of other functions of SHOPASTRO.

  11. Customer Service

    In order to improve the quality of service, when contacting our customer service team, we may ask you to provide phone number, WeChat account number and surname information in order to communicate and serve you with customer service.

(2) Personal information we actively collect in the process of providing platform services to you

Under the premise of complying with laws and regulations, in order to better provide you with services and protect the security of your account, when you browse and search in SHOPASTRO, we will collect and use the products and/or services you generate during the use of our products and/or services. The device information and log information are as follows:

Device information: We will collect your personal commonly used device information, including IP address, device model, device identification code, operating system, resolution, and telecom operator.

Log information: We will automatically collect detailed information about your use of this platform and save it as a network log, including network diagnosis, stuck information, click events, level success or failure, browsing records , click records, and URLs of potential risks, and Keep in accordance with relevant legal requirements.

(3) Authorization and consent of personal information of end users

You know very well that for the purpose of using the platform, you need us to collect, store, and process personal information from end users of your products. Therefore, you must commit to:

  1. You have obtained sufficient and necessary authorizations, consents and permits from end users to allow us to directly collect and use their personal information for the purpose of performing our services ;

  2. You have obtained sufficient and necessary authorization, consent and permission from the end user to allow us and our partners to perform de-identification analysis and aggregate processing of the collected personal information of the end user;

  3. You have complied with and will continue to comply with applicable laws, regulations and regulatory requirements, including but not limited to formulating and publishing relevant policies on personal information protection and privacy protection;

  4. You have provided end users with an easy-to-operate selection mechanism to inform end users how and when they can exercise their options, and explain how and when they can modify or withdraw the options after exercising their options, so that users can choose to agree or not Agree to collect and use their personal information for commercial purposes.

  5.  You have told the end user how to exercise the rights of the end user to you (how to access, correct their personal information, exercise the right to delete, change the scope of their authorization and consent, etc.). Your end users will not have any form of appeals, petitions, complaints, etc. against us because we process their personal information in accordance with this policy. If you ask us, you will be responsible for solving the problem for the end user.

If you violate the above commitments and cause your end users to claim any form of claims or claims against us, or cause us to be involved in legal or administrative procedures, you will be responsible for a full settlement and compensation for any form of damage we may suffer as a result loss.

(4) Exceptions for obtaining authorization and consent

According to laws and regulations, personal information collected and used in the following situations does not require the consent of the personal information subject:

  1. Related to fulfilling obligations stipulated by laws and regulations;
  2. Directly related to national security and national defense security;
  3. Directly related to public safety, public health, and major public interests;
  4. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
  5. It is related to protecting the life, property and other major legal rights of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the person;
  6. The personal information involved is disclosed by the subject of personal information to the public;
  7. Necessary for signing and performing contracts according to the requirements of the subject of personal information;
  8. Collecting personal information from legally publicly disclosed information, such as through legal news reports, government information disclosure, etc.;
  9. Maintaining what is necessary for the safe and stable operation of our platform, such as discovering and disposing of malfunctions of our platform products and/or services;
  10. Other circumstances stipulated by laws and regulations.

2. How to use cookies and other similar tracking technologies

(1) What is Cookie

A cookie is a small file stored in the personal information subject’s computer, mobile phone or other smart terminal device by the website server when the personal information subject logs on to the website or browses the network content. It usually contains identifiers, site names, and some numbers and characters. When the subject of personal information visits the corresponding website again, the website can identify the browser of the subject of personal information through cookies. Cookies may store user preferences and other information.

(2) How to use cookies

When personal information subjects use our website, we may collect the personal information subject’s device model, operating system, device identifier, and login IP address information through Cookies or similar technologies, and cache the personal information subject’s browsing information and click information to view The network environment of the subject of personal information. Through cookies, we can identify the identity of the personal information subject when the personal information subject visits the website, and continuously optimize the user-friendliness of the website, and make adjustments to the website according to the needs of the personal information subject. The subject of personal information can also change the settings of the browser so that the browser does not accept cookies on our website, but this may affect the use of some functions of the website by the subject of personal information.

On the SHOPASTRO website, with the help of cookies and other similar technologies, we can identify whether the personal information subject belongs to our user or end user each time the subject of personal information uses our products and/or services, without having to log in again on each page And verification.

(3) How to manage cookies

Personal information subjects can manage or delete certain types of tracking technologies according to their own preferences. Many web browsers have a "Do Not Track" function, which can issue a "Do Not Track" request to a website.

In addition to the controls we provide, personal information subjects can also choose to enable or disable cookies in the Internet browser. Most Internet browsers also allow the subject of personal information to choose whether to disable all cookies or only third-party cookies. By default, most Internet browsers accept cookies, but this can be changed. For details, refer to the help menu in the Internet browser or the documentation provided with the device.

The following link provides instructions on how to control cookies in all major browsers:

-Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

-IE: https://support.microsoft.com/en-us/help/260971/description-of-cookies

-Safari (desktop version): https://support.apple.com/kb/PH5042?locale=en_US

-Safari (mobile version): https://support.apple.com/en-us/HT201265

-Firefox browser: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies

-Opera: https://www.opera.com/zh-cn/help

If the subject of personal information uses other browsers, please refer to the documentation provided by the browser manufacturer.

On our website, the subject of personal information can delete the existing tracking technology by clearing the cache.

When the personal information subject browses the page without logging in, in order to provide the corresponding service to the personal information subject, we will collect the cookie information necessary to realize the browsing function , but the cookie information will be deleted within one month.  

Personal information subjects are requested to be aware that if they refuse to use or clear existing tracking technology, they need to personally change user settings during each visit, and we may not be able to provide personal information subjects with a better experience, some services It may also not work properly.

3. How do we entrust the processing, sharing, transfer, and public disclosure of personal information subjects' information

(1) Entrusted processing

In order to provide you with more complete and higher-quality products and services, certain functions may be provided by our technical service partners, and we may entrust partners (including technical service providers) to process certain personal information of personal information subjects . (For example, when you use SHOPASTRO number when paying or automatic debit function, or your end users to make payments through outlets operating in SHOPASTRO you created, we may entrust a third party payment companies handle some of your personal information.) On For companies, organizations and individuals that we entrust to process personal information, we will sign strict confidentiality agreements with them to clarify data processing matters, processing periods, nature of processing, processing purposes, and responsibilities of both parties, etc., and require partners to only follow our requirements and this policy And any other relevant confidentiality and security measures to handle personal information. If you refuse our suppliers to collect personal information necessary to provide services when providing services, you or your end users may not be able to enjoy the services provided by that supplier while using our products and/or services. For example, we will hire service providers to assist us in completing real-name authentication.

(2) Sharing

Unless one or more of the following circumstances exist, we will not share personal information with any third-party company, organization or individual:

  1. Based on the request made by the personal information subject, or the express authorization or consent of the personal information subject obtained in advance;

  2. Relevant to our fulfillment of obligations stipulated by laws and regulations;

  3. Directly related to national security and national defense security;

  4. Directly related to public safety, public health, and major public interests;

  5. Directly related to criminal investigation, prosecution, trial, and execution of judgments

  6. In order to protect the life, property and other major legal rights of the personal information subject or other individuals, but it is difficult to obtain the consent of the person;

  7. Personal information that the subject of personal information discloses to the public on his own initiative;

  8. Collecting personal information from legally publicly disclosed information, such as through legal news reports, government information disclosure, and other channels.

  9. Sharing necessary information with our affiliates and partners: We will only share personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share individuals who are necessary to provide services to you or your end users information. We will not share personal information that can identify the subject of personal information, unless otherwise stipulated by laws and regulations. Different from the partners under entrusted processing, the shared partners are data controllers who will process personal information after obtaining the consent of the personal information subject in their own name. The partner may have its own independent privacy policy and user service agreement. We recommend that you read and abide by the user agreement and privacy policy of the shared partner. The following is the details of the information we share with third parties:

A. Sharing with affiliated companies: In order to facilitate us to provide you with platform products and/or services based on your SHOPASTRO account, recommend information that may be of interest to you, identify abnormal user accounts, and protect the personal and property safety of SHOPASTRO affiliates or other users or the public To avoid infringement, the personal information of you and your end users may be shared with our affiliated companies with the consent of you and your end users. We will only share necessary personal information and are bound by the purpose stated in this policy. If we share sensitive personal information or the affiliate company changes the purpose of using and processing personal information, we will again seek authorization from you and your end users agree.

B. Share with authorized partners:

  1. Authorized partners for advertising. Unless authorized by you, we will not share the personal information of your end users with partners that provide advertising services. We will provide these partners with information about the coverage and effectiveness of their advertising, but we will not provide personally identifiable information about your end users, or we will aggregate this information so that it will not identify individual end users. Such partners may combine the above information with other data they obtain legally for advertising or decision-making recommendations.

  2. Authorized partners of statistical analysis services. Unless authorized by you, we will not share the personal information of your end users with partners that provide statistical analysis services. We will provide aggregated information to these partners so that it does not identify individual end users. Such partners may combine the above information with other data they obtain legally for statistical analysis.

  3. Authorized partners of payment cooperation. When you need to use a credit card, debit card, or an online payment method supported by other platforms to use some of SHOPASTRO’s payment or subscription features for deduction, the deduction service will be through a partner bank or third-party payment company, etc. Provide it. We will provide these partners with the necessary information to achieve the deduction function, and will not provide additional personal information.

  4. Other suppliers, service providers and other partners. We send information to other suppliers, service providers, and other partners that support our business. This support includes providing technical infrastructure services, providing customer services, payment convenience, or conducting academic research and surveys. We will agree strict data protection measures with them, and order them to process personal information in accordance with our instructions, this policy and any other relevant confidentiality and security measures.

You are reminded that this platform may contain functions provided by third parties or links to websites and services provided by third parties. The regulations and procedures described in this policy do not apply to third-party websites. Any information you provide to third-party websites or services will be directly provided to the operators of these services. Even if you access through this platform, you must comply with the privacy policies and user agreements (if any) applicable to the operators. We are not responsible for the content, personal information and security measures and policies of third-party websites or services. We recommend that you understand the privacy policy and user agreement of a third party before providing information.

(3) Transfer

In principle, we will not transfer the control of personal information to other companies, organizations or individuals, except in the following cases:

  1. Based on a request made by the subject of personal information, or your express authorization or consent obtained in advance;

  2. Relevant to our fulfillment of obligations stipulated by laws and regulations;

  3. Directly related to national security and national defense security;

  4. Directly related to public safety, public health, and major public interests;

  5. Directly related to criminal investigation, prosecution, trial, and execution of judgments;

  6. In order to protect the life, property and other major legal rights of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the person;

  7. Personal information that the subject of personal information discloses to the public on his own initiative;

  8. Collecting personal information from legally publicly disclosed information, such as through legal news reports, government information disclosure, etc.;

  9. Transfer in the event of company acquisition, merger, reorganization, bankruptcy, or change of the operating entity.

Please be aware that if the transfer is really necessary for the above reasons, we will inform you of the purpose, type, and transferee of the information before the transfer (if sensitive information is involved, we will also inform the content of the sensitive information involved), and Transfer after obtaining your consent, except as otherwise provided by laws and regulations. After the change, the operating entity will continue to perform the responsibilities and obligations of the personal information controller; if the company goes bankrupt or shuts down and there is no takeover party, we will delete or anonymize your personal information.

(4) Public disclosure

In principle, we will not release your personal information to the society or unspecified groups of people, except for those that should be disclosed based on an agreement with you or in accordance with laws and regulations.

4. How to enable you to have the right to manage personal information

(1) Access and correction of personal information

You have the right to log in and access your SHOPASTRO account at any time to view your personal information. If you find that your personal information that we collect, store, use, and disclose is incorrect or incomplete, or under other circumstances as required by laws and regulations, you can log in https://sys.admin.myshopastro.com/admin/user/login and enter the "Personal Center" "After correcting or supplementing your personal information.

If you wish to access or correct your other personal information, or encounter difficulties in exercising the above rights, you can contact us through the methods described in Article 9 of this policy, and we will respond to your information in a timely manner after verifying your identity. Request, except as otherwise provided by laws and regulations or otherwise provided for in this policy.

(2) Delete personal information

In the following situations, you can contact customer service through the methods described in Article 9 of this policy to request us to delete your personal information, unless the data has been anonymized or otherwise provided by laws and regulations:

  1. We have collected and used personal information in violation of laws, administrative regulations, or agreements with you;

  2. If we violate laws and regulations or violate the agreement with you to share or transfer personal information to a third party, we will immediately stop sharing or transfer, and notify the third party to delete it in time;

  3. If we violate laws and regulations or violate the agreement with you to share or transfer personal information to a third party, we will immediately stop sharing or transfer, and notify the third party to delete it in time;

  4. You terminate the use of the products and/or services of this platform by means of cancellation, etc.;

  5. Other circumstances stipulated by laws and regulations.

Before deleting relevant information, we may require you to verify your identity to protect your account security. When we decide to respond to your deletion request, we will delete your information from SHOPASTRO products and/or servers as soon as possible. However, due to the requirements of the regulatory authorities to fight crime and maintain national security, we will keep your communication information and transaction records within the time limit permitted by law, but we will not conduct any use. Please be aware that we may not delete the information you need to delete from the backup system immediately, but will delete it when the backup system is updated.

(3) Cancel account

Unless otherwise provided by laws and regulations or otherwise agreed in this policy, you can contact customer service through the methods described in Article 9 of this policy to cancel your SHOPASTRO account.

Please understand and be aware that canceling your account on this platform will cause you to permanently lose access to the account and the data in the account. We will provide you with account cancellation services after verifying your identity and negotiating with you to process the assets in your account. In order to provide you with a more convenient way to log out, we will continue to optimize our products in the future and inform you through page announcements. After you cancel your account, unless you need to retain personal information in accordance with laws and regulations, we will delete or anonymize your personal information in a timely manner.

Your cancellation of your account is irreversible. Once your account is cancelled, we will no longer collect your personal information and will no longer provide you with our products and/or services. Therefore, we recommend that you choose to cancel your account carefully.

(4) Constrain the automatic decision-making of the information system

In some business functions of this platform, we may make decisions based on non-manual automatic decision-making mechanisms including information systems and algorithms. If these decisions significantly affect your legal rights, you have the right to request an explanation from us, and you can contact us through the methods provided in Article 9 of this policy.

(5) Responding to the request

In order to realize the user rights described in this article, or if you have any questions, complaints, comments or suggestions, you can contact us through the contact information provided in Article 9 of this policy. To ensure security, we may ask to verify the identity of your user before processing your request. For your request, in principle, your user identity will be verified and a reply will be made within 15 working days after receiving your request.

For your reasonable request, we do not charge fees in principle. For repeated requests within a certain period of time, we will charge a certain cost depending on the situation; for requests that require too many technical means (for example, the need to develop a new system or fundamentally change the current practice) or other significant difficulties, we Will provide you with an alternative method.

We will reject your request under the following circumstances:

  1. Relevant to fulfilling the obligations stipulated by laws and regulations;

  2. Directly related to national security and national defense security;

  3. Directly related to public safety, public health, and major public interests;

  4. Directly related to criminal investigation, prosecution, trial and execution of judgments;

  5. There is sufficient evidence to show that the user has subjective malice or abuse of rights;

  6. To protect the life, property and other major legal rights of users or other individuals, but it is difficult to obtain the authorization and consent of the person;

  7. Responding to the user's request will cause serious damage to the legitimate rights and interests of the user or other individuals or organizations;

  8. Involving trade secrets.

Please be aware that we recommend that you respond directly to requests made by end users (not direct customers of this platform) who use the products and/or services of this platform. Unless we receive your request for assistance, we will forward the request received by your end user to you or ask the end user to directly find you for help.

5. How do we save and protect personal information

(1) Preservation of personal information

  1. Shelf life

    During your use of SHOPASTRO products and/or services, we will continue to store personal information about you and your end users for you. We promise that, unless otherwise required by laws and regulations, our storage time for you and your terminal users' personal information is limited to the shortest time necessary to achieve the purpose of authorized use by you and your terminal users, unless otherwise stipulated by laws and regulations or otherwise authorized by the user. .

    If you cancel your account, voluntarily delete the above information, or we stop operations due to poor management or other reasons, we will stop collecting your personal information in accordance with laws and regulations, and delete the collected personal information or make it anonymous化处理。 Treatment.

  2. Conservation area

    In principle, we will store personal information collected and generated during operations in China, and will not transmit it across borders. Please be aware that in order to assist third-party service providers to complete their services, we may transfer your personal information to third-party service providers located overseas. In this case, we will ensure that your personal information is sufficiently and equally protected in China, and implement de-identification and other measures before cross-border data transmission.

(2) Protection of personal information

We attach great importance to the safety of your personal information. For this reason, we have adopted multi-level protection measures such as safety technical measures in line with industry standards and supporting organizational structures and management systems to prevent your personal information from being leaked, damaged, or misused to the greatest extent possible , Unauthorized access, unauthorized disclosure or modification, including:

  1.  Data security technical measures 

    In order to ensure information security, we strive to take various reasonable security technical measures to protect personal information, so that the personal information of you and your end users will not be leaked, destroyed or lost. We use encrypted transmission technologies such as SSL to protect the safety of the data during its transmission, and use proper protection mechanisms to prevent malicious attacks on the data. We adopt an encrypted storage and data authority control mechanism for personal information to prevent unauthorized access, public disclosure, use, modification, man-made or accidental damage or loss of personal information of you and your end users.

  2. Data security organization and management measures

    In accordance with the requirements of relevant laws and regulations, we have appointed a person in charge of personal information protection and a personal information protection agency. We have also established a related internal control management process, based on the principle of minimum authorization, strictly set the information access authority for the staff who may be exposed to the personal information of you and your end users, and control the scope of personal information knowledge.

    We have established an internal standard system for the safe use of data, and have also adopted strict management of employees or outsourced personnel who may have access to the information of you and your end users, including but not limited to adopting different authority controls according to different positions, and signing with them Confidentiality agreement, monitoring their operations and other measures.

    We organize employees to participate in security and privacy protection related trainings and require them to complete the required assessments to strengthen employees' awareness of the importance of protecting personal information.

  3. Guarantee of terms of cooperation agreement

    Before we collect your personal information indirectly from a third party, we will expressly require the third party to collect and process the personal information of you and your end users in written form (such as cooperation agreement, letter of commitment) after obtaining your express consent . And require the third party to make a commitment in the form of a written agreement on the legality and compliance of the source of personal information. If the third party violates the behavior, we will explicitly require the other party to bear the corresponding legal responsibility.

    Before we share the personal information of you and/or your end users with our partners, we will strictly require our partners to undertake information protection obligations and responsibilities. To this end, we will require eco-partners to sign a data processing agreement or set out the terms of data protection in the cooperation agreement signed by both parties before cooperation . The agreement strictly stipulates that partners’ confidentiality obligations for user information, including the storage, use and circulation of information, should meet our management and control requirements and accept our review, supervision and audit. Once there is any violation, we will require the other party to bear the corresponding legal liability.

  4. Security incident handling

    In the unfortunate event of a personal information security incident, we will immediately activate an emergency plan, take remedial measures, record the content of the incident, and report it in a timely manner in accordance with applicable laws and regulations. If it may cause serious damage to the legitimate rights and interests of you and/or your end users , such as the disclosure of sensitive personal information, we will inform you of the basic situation of the security incident and its possible impact, and what we have taken or will take The disposal measures, the suggestions you can choose to prevent and reduce risks, the remedial measures we provide for you and/or your end users , and the contact information of the person in charge of personal information protection and the personal information protection agency. We will promptly inform you of the above incidents by email, letter, telephone or push notification. If it is difficult to inform you one by one, we will adopt a reasonable and effective way to issue a warning notice.

    Please know and understand that the Internet is not an absolutely secure environment. We strongly recommend that you use a secure method and use a complex password to help us ensure the security of your account. If you find that your personal information is leaked, especially your account or password, please contact us immediately according to the contact information provided in Article 9 of this policy so that we can take corresponding measures to protect your information.

6. How to protect the personal information of minors

This platform only provides products and/or services to users who are over 18 years old (inclusive). We will not knowingly collect personal information of minors. If we accidentally collect information about minors, we will delete it as soon as we know it. If you believe that we may improperly hold information about minors, please contact us in accordance with the methods described in Article 9 of this policy.

7. How to update this policy

We may revise the terms of this policy in due course, and this revision forms part of this policy. If such amendments result in a substantial reduction of your rights under this policy, we will notify you through a prominent position on the homepage or send you an email or other means before the amendment takes effect. In this case, if you do not agree to this policy, or object to the modification or update of this policy, you can choose to stop using our products and/or services or cancel your account. However, please be aware that the behavior and activities before your account is cancelled and before you stop using the service are still subject to this policy.

If it involves major and substantive changes, we will notify you in a significant way based on specific circumstances.

Significant and substantial changes include but are not limited to the following situations:

Our service model has undergone major changes. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;

Your right to participate in the processing of personal information and how to exercise it has undergone major changes;

Significant changes have taken place in our ownership structure and organizational structure. Such as changes in owners caused by business adjustments, bankruptcy mergers, etc.;

Changes in the main objects of personal information sharing, transfer or public disclosure;

When our department responsible for handling personal information security, contact information and complaint channels change;

When the personal information security impact assessment report shows that there is a high risk.

8. Jurisdiction and application of law

The establishment, effectiveness, performance, interpretation and dispute resolution of this privacy policy shall be governed by Chinese laws, and the application of its conflict of laws and regulations shall be clearly excluded.

If there is any dispute or dispute between you and us, you should first settle it through friendly negotiation; if the negotiation fails, you agree to submit the dispute or dispute to the Hangzhou Internet Court for settlement through litigation.

9. How to contact us

If you have any questions, comments or suggestions about the content of this policy, you can contact us in the following ways: 1) SHOPASTRO's customer service email: shopastro@shopastro-inc.com; 2) Personal information protection full-time department email: shopastro@shopastro-inc.com; or 3) Mail the letter to: Common office address: Room 1701, Building 5, Times Future City, Cangqian Street, Yuhang District, Hangzhou City , Zhejiang Province. 

10. Keyword definition

You: Refers to seller users and/or their employees and/or other persons authorized to operate this platform who have registered and used SHOPASTRO.

Personal information: refers to various information recorded electronically or in other ways that can identify a specific natural person alone or in combination with other information or reflect the activities of a specific natural person. The personal information involved in this policy includes name, date of birth, ID number, personal biometric information , address, communication contact information, communication records and content, passwords, property information, transaction information, etc.

Personal sensitive information: refers to personal information that, once leaked, illegally provided or abused, may endanger personal and property safety, and easily lead to personal reputation, physical and mental health damage, or discriminatory treatment, including ID number, personal biometric information, bank account , Property information, credit information, whereabouts, health and physiological information, transaction information.

 

De-identification: refers to the process of technical processing of personal information to make it impossible to identify or associate you without additional information.

Deletion: Refers to the act of removing personal information from the system involved in the realization of daily business functions, so that it can be kept in a state where it cannot be retrieved or accessed. 

Anonymization: refers to the process of technical processing of personal information so that you cannot be identified or associated, and the processed information cannot be restored.

Mainland China or Mainland China: refers to the Mainland of the People's Republic of China (for the purpose of this policy only, excluding Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan Region).

NoteThis Policy is prepared Chinese and translations in other languages are for reference purpose only. If there is any discrepancy between the Chinese version and any translation in other language, the Chinese version shall prevail.