HitPaw Privacy Policy

This product is provided by HITPAW CO.,LIMITED (hereinafter referred to as "we" or " the Company", whose registered address is at RM B3,19/F TUNG LEE COMM BLDG 91-97 JERVOIS ST SHEUNG WAN HONG KONG, personal information security officer can be reached at [email protected]). We attach great importance to protecting the privacy of our users (or "you"), and we are committed to respecting and protecting the personal information we collect. This Privacy Policy explains how we collect, use, store, share and otherwise process your personal information when you use our products. This Privacy Policy will help you understand the followings:

Ⅰ. How we collect and handle your information, and what information we collect from you

Ⅱ. How we store and protect your information

Ⅲ. How we use Cookie and similar technologies

Ⅳ. How we share, transfer and disclose your personal information

Ⅴ. How you shall manage your personal information

Ⅵ. How we handle the personal information of minors

Ⅶ. How your information will be transferred

Ⅷ. Permissions of users in different regions for their personal information

Ⅸ. How the Policy will be updated

Ⅹ. How to contact us

Ⅰ. How we collect and handle your information, and what information we collect from you

1. The personal information we may need to collect and use about you regarding your use of our product includes the following two circumstances:

a. In order to provide you with the basic features of our product, we may need your permission to collect and use the necessary information. In the event that you refuse to provide the corresponding information, you will not be able to have proper access to or use our product.

b. In order to provide you with additional features of our product, you may have the option of accepting or refusing to provide us with certain information about yourself, and the type and scope of personal information collected for the basic features and additional features may differ. If you refuse to provide us with such information, you will not be able to use the additional features or reach the desired results, but this will not prevent you from using the basic features.

2. The specific scenarios in which we collect and use your information for functional purposes:

a. Visiting or using our websites/products/service

When a user visits our website/products/services, the users' click actions on the website, the pages they have visited, the date and duration of their stay on the website, the traffic-source of the users are collected. Such information is in most cases collected in an anonymous manner.

When you are using our websites/products/service, we may ask for various permissions and collect different data depending on the product. Generally, if you use our websites/products/service, depending on the features, we may ask for your permission to get access to PC system administrator, reading/writing local files, reading/writing registry, reading/writing local storage, and other accesses. The personal information we collect through the aforementioned permissions is limited to the following: device type, device name or model, device specification, device identifier, operating system and its version, software version, browser and its version, screen resolution, language setting, IP address, MAC address, ISP, size and name of the file you are working with (but not the original file documentation), log information of the operation.

b. Creating your account

You can create an account while visiting or using our websites/products/service to better enjoy the entire experience of them. When creating a new account, you may need to provide all or some of the following information: your username, E-mail address, phone number, social media accounts, country/region etc. Such information is used for account creation and user self-display, and will help you retrieve your account more easily if you encounter account problems such as loss of your account.

c. Logging in with or sharing to third party services

Signing up or logging in with a third party account(such as Google, Facebook, Apple ID etc.) or share with the aforementioned third parties. For the purposes mentioned above, you acknowledge and consent that we may acquire and collect information about you from these third parties or provide your information, such as your personal profile (ID, avatar, etc.) that is publicly available to third parties, and other information that you have agreed to authorize at the authorization page.

d. Customer service and dispute handling

When you contact us or submit a request for resolution of an ongoing sale, after-sales, or dispute, we may require you to provide the necessary personal information to verify your identity in order to ensure the security of both your account and our system. In order to easily reach you, help you with the problems in a timely manner, or to keep records of the solutions and results of such problems. We may archive your records of your communications, correspondence/calls and related content (including account information, address, email address, other contact information and other information you provide to prove the relevant facts) with us. We may also use other information about you to provide customer service and to improve the quality of said service, including information you provide when you contact customer service and information you send to us in response to a survey.

e. Crash data collecting

When a user's operation crashes while visiting or using our websites/products/services, we will ask the user individually if he/she would like to send us the original reports in order to identify the cause of the bug so that we can fix the problem. We will not collect original reports from users until they have given us their consent.

f. Personal sensitive information

Sensitive personal information such as photos of your face may be collected in using our websites/products/services, but such information is only used to enable the relevant service or features. We will use and store the aforementioned information in a lawful and compliant manner and not in any other way.

3.On one hand, we need the access to the aforementioned permissions and information of you to provide you with specific services. Also, we need them for internal statistics and analysis, to analyze your use of our websites and products and understand how they are used. By doing such, we are expected to improve our products and services, as well as the user experience. If you declined to such access or disagree to our collecting of such information, you will not be able to use such features, and we will give responses to your requests and needs in a timely manner. You will not be able to use the specific service, but it will not affect your regular use of our other services.

Ⅱ. How we store and protect your personal information

We will only keep your personal information and data for such period of time as is necessary to fulfill the purposes described in the Policy, unless a longer keeping time is required or permitted by applicable law.

We take reasonable measures to help protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration or destruction, and please help us keep your account and personal information safe by using sophisticated passwords.

Please be aware that the systems and communication networks you use to access our products/services may be subject to security issues in other steps beyond our control. Please understand that in the Internet industry, due to the limitations and rapid development of technology and the possible existence of malicious attacks, even if we do our best to strengthen security measures, it is not always possible to guarantee 100% security of information.

Ⅲ. How we use Cookie and similar technologies

To keep our websites and products working properly, and to help make your visit experience easier and to recommend information that may be of interest to you, we may store small data files called Cookie on your computer or mobile device. Cookie allows the websites to store your preferences and other data to help you save yourself the hassle of filling in personal information and entering your search history repeatedly. And we may also use such technology to recommend, display and push contents of interest to you. We will not use Cookie for any purposes other than those described in this Privacy Policy. You can manage or delete Cookies to your preference. Most browsers have features to block Cookies and you can clear all Cookies saved on your computer with the browser's settings, but please note that if you disable all cookies, some parts of our websites may not work properly. For more information on how to change your browser settings, please visit the relevant settings page of the browser you are using.

IV. How we share, transfer and disclose your personal information

In order to ensure the implementation of our product-related features and the safe and stable performance of our apps, and because some features of our products cannot be executed by us alone, we may share or entrust some of your personal information with third parties such as our partners in order to ensure the smooth implementation of our product features. You agree that we may share your personal information with affiliates that support our features, and with third parties that we integrate or access, for the purpose of providing the services to you. The support provided by these third parties includes providing us with data analysis, data storage, payment processing, image processing support. Our affiliates of our features are not authorized to use your personal information for purposes other than those set forth in this Privacy Policy and the purposes set forth herein. They shall obtain your authorized consent separately if they wish to change the purposes for which personal information is processed.

You agree that, in the event of merging, separating, acquiring or liquidating, your personal information may be transferred as part of such transaction. And we will ensure the confidentiality of such information at the time of transfer, and ensure that you will be informed of the name and contact information of the recipient. And we will require the new recipient of your personal information to remain subject to this personal information protection policy, or we will require the recipient to ask for your authorized consent again.

We may disclose all of your information for subsequent reasons: in response to a subpoena, court order, legal process, law enforcement request, legal claim, or government investigation, to protect and defend the rights, interests, and safety of the platform, our affiliates, users, or the public.

V. How you shall manage your personal information

You have the right to access, correct, and delete the information we collect about you.If you are unable to do so, or have any questions about Personal Information we have collected and/or shared about you, or would like to withdraw your consent for our processing (i.e. entirely delete your account) please contact us at: [email protected].

We will act on the User’s requests and provide information free of charge, except where the requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case we may charge a reasonable fee (taking into account the administrative costs of providing the information or communication, or taking the action requested), or refuse to act on the request.

Ⅵ. How we handle the personal information of minors

If you are a minor, you shall use our services with obtaining prior consent of your parent or legal guardian (collectively, "guardian"). We recommend that the guardians of minors shall read this Policy carefully, and we also recommend minors to obtain guardians’ prior consent and guidance before submitting personal information in your use of our services. If you are the legal guardian of a minor, please ensure that the minor in your custody is using our products or services with your authorized consent. If you have questions about the personal information of a minor in your custody, please contact us through the means set forth in this Privacy Policy.

We are not directed to children under the age of 13 and we do not knowingly collect Personal Information from children under the age of 13. If we learn that we have collected Personal Information of a child under the age 13, we will take reasonable steps to delete such information from our files as soon as is practicable, unless we have a legal obligation to retain it. Please contact us if you believe we have any information from or about a child under the age of 13: [email protected].

Ⅶ. How your information will be transferred

Given the global reach of our business and the fact that we may share or entrust the processing of some of your personal information with third parties such as other partners, we may transfer your data to servers or data centers in the United States, the European Union, Japan and outside of such locations for storage and/or processing. We ensure that users' personal data processed by us or our partners is handled in a secure manner and protected against unauthorized access, loss or destruction, unlawful processing, and any processing policies that are inconsistent with the purposes set forth in this Privacy.

Ⅷ. Permissions of users in different regions for their personal information

to request details of the information we hold about you and how we process it
to have your personal information rectified if it is inaccurate or deleted
to restrict our processing of your personal information
to withdraw a previously provided consent to processing of your personal information
to stop unauthorized transfers of your personal information to a third party
to have your personal information transferred to another person
to complain about our processing of your personal information to a local supervisory authority

It is important to be aware that these rights may not be absolute. For example, if you withdraw your consent to our processing of your personal information, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

HITPAW CO.,LIMITED is the controller of your information. In the event of a data leak, we will inform the regulatory authorities and users of the leaked information in a timely manner. If you have any questions about the matters covered by this policy, please contact our Data Protection Officer at [email protected].

Rights regarding personal information for California residents

Pursuant to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), California residents receive certain rights with respect to their personal information, as described below. These rights are not absolute and are subject to certain exceptions more fully set forth in the CCPA. California residents have the right not to receive discriminatory treatment from us for the exercise of the privacy rights conferred by the CCPA.

Right to know about personal information collected, disclosed, or sold

Each California resident has the right to request, subject to certain exceptions described in the CCPA, that we disclose to that resident:

the categories of personal information we have collected about them,
the categories of sources from which the personal information is collected,
the business or commercial purpose for collecting or selling the personal information,
the categories of third parties with whom we have shared the personal information,
the specific pieces of personal information we have collected about them (collectively, a “Request to Know”).

To make such a Request to Know, You can send an email to customer service email: [email protected], or fill out our request form here.

In the past twelve months we have collected, and in the future we will continue to collect, the categories of personal information cited in the section entitled “The personal information we collect” above. This includes the following categories of personal information set out in the CCPA: identifiers, personal information described in Section 1798.80 of the California Civil Code, characteristics of protected classifications under California or federal law, Internet or other electronic network activity information, geolocation data, professional or employment-related information and sensitive personal information. We collect this information from the sources described in the section entitled “How we collect personal information” above, use this information as described in the section entitled “How we use personal information” above, and share this information with third parties as described in the section entitled “Sharing personal information” above.

We do not sell your personal information as defined under the CCPA or share your personal information for cross-contextual behavioral advertising purposes and we do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. We do not use or disclose sensitive personal information for purposes other than those permitted purposes specifically identified in the CCPA and its implementing regulations.

Right to request deletion of personal information

Each California resident has the right to request the deletion of their personal information that we collect or maintain (a “Request to Delete”), subject to certain exceptions set forth in the CCPA. To make such a Request to Delete,you can send an email to customer service email: [email protected], or fill out our request form here.

Right to correct inaccurate personal information

Each California resident has the right to request the correction of any inaccurate personal information that we maintain (a “Request to Correct”), subject to certain exceptions set forth in the CCPA. To make such a Request to Correct, you can send an email to customer service email: [email protected], or fill out our request form here.

Process for verifying requests of California residents

In order to protect your privacy and security, prior to completing any Request to Know, Request to Delete or Request to Correct that you may submit, we must verify your identity. We will verify your identity by asking you to provide certain data that we have already collected from you to confirm that they match our records. In certain instances, additional verification steps may be required.

Authorized agents

California residents have the right to designate an authorized agent to make a request under the CCPA on their behalf. Prior to completing a request made by such an authorized agent, we require that you provide your authorized agent with written permission to submit such a request and require that you or your authorized agent provide us with a copy of such written permission. Additionally, we require that you verify your identity pursuant to the procedure described above.

Keeping personal information

Your personal information will be retained in accordance with our Data Privacy Policy.

We retain personal information of different types, or relating to different categories of people, for different periods, taking into account its business purpose.

The periods for which we retain information are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used. We take into account legal and regulatory provisions which require information to be retained for a minimum period.

If you have any questions on the matters covered in this policy, you can send an email to customer service email: [email protected].

Ⅷ. How the Policy will be updated

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of the new Privacy Policy, posting the new Privacy Policy, or providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you visit the Platform to stay informed of our privacy practices.

Ⅸ. How to contact us

If you have any questions, inquiries, opinions, suggestions or complaints regarding the Policy or personal information protection, you can reach us by means of:

a. send E-mails to our customer service mailbox: [email protected]

b. submit online forms to https://support.hitpaw.com/#/

Last updated: August 2, 2023