NineData Privacy Policy

Effective Date: April 10, 2023

NineData (referred to as "the platform" or "we" below) is a one-stop data management solution and service provider offered to users (referred to as "you" below) by Jiuzhang Arithmetic (Zhejiang) Technology Co., Ltd. (registered address: 11th Floor, Building 3, Haizhi Centre, Cangqian Street, Yuhang District, Hangzhou, Zhejiang Province). We understand the importance of personal information to you. We attach great importance to protecting your personal information and privacy. Through this privacy policy (referred to as "this policy" below), we would like to introduce how we will handle your personal information when you use our services, as well as the ways we provide you with access, correction, deletion, and protection of this information. This policy is closely related to your use of our products/services, and we recommend that you read and understand the full content of this policy carefully and make appropriate choices. For clauses and personal information in this policy that are of significant importance to your rights and interests, we will highlight them in bold and/or underline in the text to draw your attention.

The main points are as follows:

In order to facilitate your understanding of the types and purposes of information we need to collect when you use our services, we will explain them to you one by one in combination with specific services.
In order to provide you with the services you need, we will collect your information in accordance with the principles of legality, legitimacy, necessity, and good faith.
You can access and manage your information, set privacy features, cancel your NineData account, or make complaints and reports through the methods described in this policy.

Overview

This policy will help you understand the following:

I. How we collect and use your personal information

II. How we use cookie technology

III. How we store your personal information

IV. How we protect your personal information

V. How we provide personal information to third parties

VI. How you can exercise your rights to your personal information

VII. How we protect the information of minors

VIII. Application and update of this policy

IX. Explanation of key terms in this policy

I. How We Collect and Use Your Personal Information

1.1 According to relevant laws, regulations, and national standards, we may legally process your personal information in the following circumstances:

(1) With your consent;

(2) When it is necessary for the conclusion and performance of a contract at your request;

(3) When it is necessary to fulfill legal obligations, such as anti-money laundering, anti-terrorism financing, real-name authentication, and other necessary information required by relevant laws and regulations;

(4) When it is directly related to national security or national defense security;

(5) When it is necessary to protect the life, health, and property safety of natural persons in response to public health emergencies or emergency situations;

(6) When it is directly related to criminal investigation, prosecution, trial, and execution of judgments;

(7) When the personal information collected is made public by you;

(8) When personal information is collected from legally disclosed information, such as lawful news reports, government information disclosure, and other channels;

(9) When it is necessary to maintain the security and stable operation of the services provided, such as discovering and handling faults in products or services;

(10) When it is required by other laws and regulations.

Please note that when the processing of your personal information falls under the circumstances from (2) to (10) above, we may not need to obtain your consent based on the requirements of applicable laws and regulations.

1.2 Helping You Become Our User and Providing Account Services

1.2.1 Account Registration and Login

To comply with legal requirements, you must register and log in to a NineData account to use the platform's related database services.

When you create an account on the NineData website, you need to provide your phone number or email to create an account, set and confirm your login password. If you choose to create an account through your phone number, you need to provide a phone number within the territory of the People's Republic of China. The phone number or email you provide will be used to receive verification codes for registration, login, account binding, and password retrieval, and it will be one of the contact methods specified by NineData to receive related business notifications (such as new product launches, service changes, etc.). At the same time, NineData may use this contact method to send you marketing promotions, activity notifications, product promotion, or to communicate with you about business matters.

1.2.2 Account Recovery

When using the account recovery feature, in order to protect the security of your account, we require you to provide a verification code for your phone number or email to verify the account.

1.3 Invoice Mailing

If you use our paid services (NineData Enterprise Edition), and you request a paper invoice to be issued and sent to you, we require you to provide your invoice mailing address, including the recipient's name, detailed address, postal code, phone number, etc. NineData can use this information to send you the invoice. At the same time, we will disclose your order-related delivery information to relevant logistics companies, and synchronize the logistics and delivery information with logistics delivery entities selected by the service provider. We need to promptly obtain and confirm delivery progress and status, and you agree that we may collect information related to delivery progress from the logistics company and relevant service providers.

1.4 User Services and Service Quality Improvement

In order to improve your product experience, we may collect device information when you use our products/services for device confirmation.

1.2.2 Account Recovery

When using the account recovery feature, in order to protect the security of your account, we require you to provide a verification code for your phone number or email to verify the account.

1.3 Invoice Mailing

1.4 User Services and Service Quality Improvement

In order to improve your product experience, we may collect device information when you use our products/services for device confirmation.

1.5 Log Information

When you use our products/services, we will automatically collect detailed usage information about our services as operation logs, including your actions, time of use, service response time, operational steps, IP address, language used, web page history, etc.

1.6 User Feedback

In order to improve your service experience and improve our service quality, or to recommend better or more suitable services to you, we may collect your operation records when using our services, the information you provide when contacting our customer service team, and the information you send to us when participating in surveys.

II. How We Use Cookie Technology

To provide you with a more convenient browsing experience, when you visit the NineData website or use the products/services provided by NineData, we may identify your identity through small data files, which can help you save the steps of repeatedly entering registration information or help judge the security status of your account. These data files may be cookies, Flash cookies, or other local storage provided by your browser or associated applications (hereinafter referred to as "cookies"). Please understand that some of our services can only be implemented through the use of cookies. If your browser or browser add-ons allow, you can modify the level of acceptance of cookies or refuse NineData's cookies. The "Help" section of most browser toolbars will tell you how to prevent your browser from accepting new cookies, how to let your browser notify you when you receive a new cookie, or how to completely disable cookies. In addition, you can close or delete Flash cookies and similar data used by browser add-ons by changing the settings of your browser add-ons or by visiting the provider's website. However, this action may affect your access to the NineData website and the use of NineData-provided services.

III. How We Store Your Personal Information

3.1 The personal information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China, and we will not transfer such information overseas.

3.2 We will only retain your personal information for the necessary period as described in this Policy and within the time limit required by laws, regulations, and supervisory requirements, such as the requirement under the "Electronic Commerce Law of the People's Republic of China" to retain product and service information and transaction information for not less than three years from the completion of the transaction. If you cancel your account or the necessary retention period expires, we will delete or anonymize your personal information we hold according to the requirements of applicable laws and regulations.

3.3 If we terminate our products/services, we will provide you with at least thirty days' prior notice and delete or anonymize your personal information we hold according to the requirements of applicable laws and regulations after the termination of products/services.

IV. How We Protect Your Personal Information

4.1 In order to ensure the security of your information, we will take various reasonable and necessary measures to protect it after collecting it. For example, in the technical development environment, we only use de-identified information for statistical analysis. When providing research reports to third parties, we will de-identify the information contained in the reports. We will separate de-identified information from information that can be used to re-identify individuals to ensure that individuals are not re-identified in subsequent processing of de-identified information.

4.2 We promise to ensure information security protection reaches the industry's leading security level. To safeguard your information security, we are committed to using various security technologies and supporting management systems to minimize the risks of information leakage, destruction, misuse, unauthorized access, unauthorized disclosure, and alteration. For example, we use network security layer software (SSL) for encrypted transmission, information encryption storage, and strict restrictions on data center access. When transmitting and storing sensitive personal information (including personal biometric information), we will adopt security measures such as encryption, permission control, and de-identification/anonymization.

4.3 We have established relevant internal control systems and adopt the principle of minimum necessary authorization for personnel who may have access to your information. We continuously monitor the behavior of personnel who handle your information, provide them with training on relevant laws and regulations, privacy security guidelines, and strengthen security awareness, and organize all staff to participate in security lectures every quarter. In addition, our corresponding network/system has passed the evaluation of the national network security level protection. We also hire external independent third parties to evaluate our information security management system every year.

4.4 We have formulated a personal information security incident emergency plan and regularly organize internal personnel to undergo emergency response training and drills to master their job responsibilities and emergency response strategies and procedures. In the event of a personal information security incident, we will inform you in a timely manner in accordance with legal and regulatory requirements, including the basic situation and possible impact of the security incident, the measures we have taken or will take to dispose of it, suggestions for you to prevent and reduce risks, and remedies for you. We will promptly inform you of the relevant situation by sending emails/short messages, etc. If it is difficult to inform individuals one by one, we will adopt reasonable and effective methods to publish announcements. At the same time, we will proactively report the disposal of personal information security incidents to regulatory authorities. If your legitimate rights and interests are harmed, we will bear corresponding legal responsibilities.

4.5 Please be sure to properly safeguard your NineData login name and other identity elements. When you use the products/services we provide, we will identify your identity through your login name and other identity elements. Once you disclose the aforementioned information, you may suffer losses and may be disadvantaged. If you find that your login name and/or other identity elements may or have been leaked, please contact us immediately so that we can take corresponding measures to avoid or reduce related losses.

4.6 After you terminate the use of NineData services, we will stop collecting and using your personal information, except as otherwise required by law or regulatory authorities. If we cease operation, we will promptly stop collecting your personal information and notify you of the cessation of operation individually or in the form of an announcement, and delete or anonymize the personal information we hold.

V. How We Disclose Personal Information to Third Parties

5.1 Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following cases:

(1) With your explicit consent;

(2) According to laws, regulations, or mandatory administrative or judicial requirements;

(3) In cases of asset transfers, acquisitions, mergers, reorganizations, or bankruptcies that involve the transfer of personal information, we will inform you of the relevant circumstances and request that the new entity holding your personal information continue to be bound by this policy. If the purpose or processing of your personal information changes, we will require the new entity to obtain your explicit consent again.

5.2 Public Disclosure

In principle, we will not publicly disclose your information, except where there are clear provisions in laws or administrative regulations. If public disclosure is necessary, we will inform you of the purpose of the disclosure, the type of information to be disclosed, and any sensitive information that may be involved, and obtain your explicit consent.

VI. How to exercise your personal information rights

During your use of our products/services, in order to facilitate your access and management of your information while protecting your personal information rights, we provide corresponding operation settings on our official website. You can refer to the following guide for operations.

6.1 Access, correction, and supplementation

You have the right to access, correct, and supplement your personal information, except as otherwise provided by laws and regulations. After logging into your account on our official website, you can manage your information in the following ways:

Account information: You can access, correct, and supplement your personal information and account information by visiting "Avatar > Modify Information". You can also retrieve and correct your login password by clicking "Forget Password" on the NineData login page.

If you find that the corresponding information is incorrect, you can modify your information by following the page prompts, or you can click on the customer service entrance in the lower left corner of the NineData console to contact online customer service for correction. For security and identity verification reasons or according to laws, regulations, and regulatory requirements, you need to be verified before modifying your verified name or bound mobile phone number.

6.2 Deletion

You can delete some of your information through the path specified in 6.5, or apply to cancel your account to delete all of your information. If you find that our collection and use of your personal information violates laws, regulations or agreements with you, you can contact customer service to request the deletion of personal information.

6.3 Account cancellation

You can enter the account cancellation application process by contacting our official customer service. When you meet the agreed account cancellation conditions and cancel a service-related account, we will delete all your personal information in that account according to legal requirements. However, if there are cases where related personal information cannot be deleted due to the retention period specified by laws and regulations or other lawful reasons, we will stop processing it except for storage and necessary security protection measures.

6.4 Despite the above provisions, we may not be able to respond to your request in the following situations according to relevant laws, regulations and national standards:

(1) Directly related to national security and defense;

(2) Directly related to public safety, public health, and major public interests;

(3) Directly related to criminal investigation, prosecution, trial, and execution of judgments;

(4) There is sufficient evidence that you have subjective malice or abuse of rights;

(5) Responding to your request will cause serious damage to the legitimate rights and interests of other individuals or organizations.

6.5 If you have any questions about this policy or any complaints or opinions regarding the processing of your personal information, you can contact us through the following channels:

(1) Online customer service: the customer service entrance in the lower left corner of the NineData console

(2) Mailing address: Room 1102, Building 3, Haizhi Centre, Cangqian Street, Yuhang District, Hangzhou City

The customer service department, together with the privacy protection responsibility department, will reply to you promptly. To provide timely service response, we recommend that you use the above paths to contact us.

To ensure the security of your information, we need to verify your identity and credential information first. We have established a customer complaint management mechanism, including tracking processes. We will respond within 15 working days at the latest.

VII. How we protect minors' information

7.1 We take the protection of minors' personal information very seriously. We expect parents or guardians to guide minors in using our services. We will protect the confidentiality and security of minors' information in accordance with relevant national laws and regulations.

7.2 If you are a minor, we recommend that you have your parents or guardians read this policy and use our services or provide us with your information only with their consent. For information collected with the consent of parents or guardians, we will use or disclose it only as permitted by law, with the explicit consent of parents or guardians, or as necessary to protect your rights. If your guardian does not agree to your use of our services or the provision of information to us under this policy, please immediately stop using our services and notify us promptly so that we can take appropriate action.

7.3 If you are a parent or guardian of a minor and have any questions about how we handle their information, please contact us using the contact information provided above.

7.4 Special notice: For children under 14 years old and their guardians, please use our services or provide information to us only with the consent of the child's parents or guardians when registering for a NineData account and using our services.

VIII. Applicability and Updates to this Policy

8.1 In order to provide you with better services, the products/services we provide may change from time to time, and this policy will also be updated accordingly. We will also update the relevant terms of this policy in accordance with changes in national laws and regulations. The updated policy will take effect from the date of the announcement of the update.

8.2 We will update this policy in a timely manner if the following significant changes occur:

(1) Our basic situation changes, such as changes in ownership due to mergers, acquisitions, or reorganizations;

(2) The scope, purpose, and rules of collecting, storing, and using personal information change;

(3) The objects, scope, and purpose of providing personal information to third parties change;

(4) The way you access and manage personal information changes;

(5) Data security capabilities and information security risks change;

(6) User inquiry and complaint channels and mechanisms, as well as external dispute resolution organizations and contact information, change;

(7) Other significant changes that may affect your personal information rights.

8.3 If this policy is updated, we will notify you by push notification on the console, email/message, or by posting an announcement on the official website. To ensure that you receive timely notifications, we recommend that you notify us promptly when your contact information changes. If you continue to use our products/services after the updated policy takes effect, you indicate that you have fully read, understood, and accepted the updated policy and are willing to be bound by it.

IX. Explanation of Key Terms in this Policy

Personal Information: Refers to all kinds of information related to an identified or identifiable natural person that is recorded electronically or by other means, excluding anonymized information.

Sensitive Personal Information: Refers to personal information that, if disclosed or illegally used, is likely to harm a natural person's personal dignity or endanger their personal, property safety. This includes information such as biometric data, religious beliefs, specific identities, medical and health information, financial accounts, travel records, and personal information of minors under 14 years of age.

Processing of Personal Information: Includes the collection, storage, use, processing, transmission, provision, disclosure, deletion, and other handling of personal information.

Account Information: Refers to the elements of NineData account-related information used to identify you, including your ID, phone number, password, SMS verification code, avatar, and nickname information.