[Special Note] Before using this product and / or service, please carefully read and fully understand this policy (especially in bold or underlined) and determine our processing rules for your personal information. If you understand and agree to accept this policy, you can click ‘Agree’ to accept our services.
1.1 This policy applies to :
(a) Users who use the services provided by the ‘insMind’;
(b) ‘insMind’ website or app forms.
1.2 Please note that this policy does not apply to the following situations:
(a) The services provided to you by the third-party application system integrated through page embedding, link and jump are not applicable to this policy. We recommend that you view the information protection claims for third party application systems to see how they handle your information. For the personal information provided by you to the third-party application system or actively shared and disclosed to others, the consequences arising therefrom shall be borne by yourself;
(b) All kinds of personal information that we handle on behalf of enterprises when providing services do not apply to this policy.
2. Types of Data collected
We will follow the principle of "reasonable, relevant and necessary" and collect information on the premise of your consent, and will not collect information prohibited by laws and regulations. At the same time, we are in the business involving personal information, has been careful to handle the types of personal information, purpose, way to carry out the necessity assessment, as far as possible for the necessary information from the source to prevent collection, unavoidable, clearly inform you to collect the necessary information specific purpose, by your independent judgment whether agree to processing. You may reject the information necessary to implement business functions or as required by laws and regulations without affecting other functions or services. As part of our anti-corruption compliance program and as a legal obligation, if necessary, we will use the information collected on the basis of your valid consent.
During your use of the product and / or services, we will obtain your personal information through the following ways:
(a) Information you agree to provide directly: we may collect and store the information you provide to us when using your products and / or services, including information provided when you fill in information online in our pages, when applying for products and / or services or when contacting us, and information about your transactions and activities generated when using our services.
(b) Information we collect: In the process of using this product / service, we will collect the information sent to us by your computer, mobile phone and other access devices.
(c) information obtained from related parties, partners, etc: to jointly provide you with products and / or services or improve the quality of products and services or for the safety of products and services, we may, in accordance with the provisions of laws and regulations or based on your effective authorization to receive your personal information and other information from affiliated companies, partners and other trusted third party suppliers. We will ask the personal information provider to explain the source of personal information in advance, and confirm the legality of the source of personal information and the scope of authorized consent. If the personal information processing activities required for the business are beyond the scope of the authorized consent obtained, we will obtain your express consent within the reasonable period after obtaining the personal information or before processing the personal information, or obtain your express consent through the personal information provider.
If we have to use your personal information beyond your consent , we will inform you again and obtain your express consent before using your personal information. Please note that the type of personal information we collect varies with the content of the product and / or service, subject to the actual provision of the product and / or service.
2.1 Business Scenario
Register and login
When you register "insMind" products and / or services, according to the registration method you choose, we will collect your relevant information as needed to help you complete the registration of "insMind" account, so that you can synchronize your data when you log in with different devices of insMind.
1. If you use your mobile phone number to register and log in to "insMind", we will collect your mobile phone number, and you need to provide the SMS verification code we sent to you for verification operation. Your encrypted cell phone number will serve as your default nickname. If you refuse to provide your mobile phone number for verification, you can also choose the third-party account associated login method(such as your email).
2. If you use a third-party account to log in to "insMind", you need to authorize "insMind" to read and share the network identity information you publish on the third-party platform on the premise of complying with relevant laws and regulations. At the same time, the nickname and profile picture provided by the third-party account will be your default nickname and profile picture. After registering your account through your mobile phone number or a third-party platform, you can also edit and improve your personal data according to your own needs.
Edit your profile
You can choose to fill in your gender, nickname, profile picture, birthday, location, personality signature information, which will help us to provide you with a more personalized experience. If you do not fill in, it will not affect your use of other functions of our products and / or services. When you upload / change your avatar, we will request your camera, storage / photo permission and collect the picture information you upload / replace. If the pictures you upload involve your sensitive personal information, which may have a great impact on your privacy and interests, please protect your privacy and avoid uploading pictures containing privacy factors or sensitive personal information. We will strictly protect the pictures you upload in accordance with the law.
2.2 Operation and safety guarantee
(a) In order to ensure the security of software service and your account, the quality and efficiency of service operation, we will collect your hardware model, operating system version number, device name, device configuration, international mobile device identification code, unique device identifier, network device hardware address, IP address, WLAN access point, Bluetooth, software version number, network access mode, type, status, network quality data, operation, use, and service log. We may associate your device information or phone number to your account number under this product and / or service.
(b) In order to prevent malicious programs, ensure service security and improve the browsing experience, we will collect the installed application information or running process information, the overall operation of the application, usage and frequency, application crash, overall installation and usage, performance data, and application source.
(c) In order to analyze the statistical indicators such as application addition, activation, retention, and performance, we may call the clipboard to conduct attribute analysis on the relevant statistical information. Please rest assured that we will not collect your privacy information.
(d) We may use your account information, equipment information, service log information and information that our affiliates and partners are authorized by you or shared according to law to judge account security, application activation activity and activities, conduct authentication, detect and prevent security incidents.
2.3 User feedback service
(a) customer service and problems: to facilitate contact with you, help you solve the problem or record related problems solutions and results, we may keep your communication / call records and related content (including account information, feedback information, order information, your other information to prove the relevant facts, or you leave contact information), if you for specific order consultation, complaints or advice, we will use your account information and order information.
(b) when you complain others or be complained by others, in order to protect the legitimate rights and interests of you and others, we have to submit your account / identity information, contact information, complaints related content to related legal departments, in order to timely solve the complaint dispute.
(c) Questionnaire survey: In order to accomplish your orders and improve service quality, we may also use other information that you provide when you contact customer service and the questionnaire reply information sent to us when you participate in the questionnaire; if you disagree, you shall refuse to participate in the questionnaire.
2.4 Description of the device authority
2.4.1 In order to ensure the smooth completion of the service provided to you, we need you to authorize the relevant system permission, the sensitive permission will not open by default, only after you explicitly agree to authorize us, we in the first call you whether the equipment permission to open and explain the purpose of permission application. You can access the system ‘Settings’ at any time to close the corresponding system permissions, and we will no longer continue to collect and use the relevant personal information based on the corresponding permissions. The permission we apply for will be consistent with the service function provided. If the business function we provide is adjusted, the equipment authority we apply for will be adjusted accordingly.
2.4.2 Please note that once you close any permission, you cancel the authorization on your behalf, which will prevent us from providing you with corresponding business function services, and directly affect your use experience. However, your decision to close the permission will not affect the previous processing of personal information based on your authorization. We hereby guarantee that if you do not select one of the above functions, unless it provides basic support for all or part of other functions (such as account login, etc.), it will not affect your normal use of other functions we provide for you.
2.5 Third-party SDK or other similar applications
2.6 We may send you messages
You know and agree that for your contact information provided during the use of the service with your consent , we may send multiple notices to one or more of them in the operation, for user message notification, authentication, security verification, user experience research and other purposes, in addition, we may provide you with related services, functions or activities, but please rest assured that if you are unwilling to accept such information, you can unsubscribe through the way provided in the message, or contact us directly. We may give you a service-related announcement if necessary (for example, if a service is suspended due to system maintenance).
2.7 Changes in the purpose of collecting and using personal information
Please understand that as our business develops, there may be some changes to the related product functions and services provided. In principle, when a new function or service is related to the function or service that we are currently providing, the personal information collected and used will be directly or reasonably related to the original processing purpose. In the case where there is no direct or reasonable correlation with the original processing purpose, if we collect and use your personal information, we will inform you in accordance with the requirements of laws, regulations and national standards in page prompts, interaction process, agreement confirmation and other reasonable ways, and obtain your consent.
2.8 Exceptions to authorized consent
Please understand that in the following cases, according to regulations and relevant laws and regulations:
Related to our performance of the obligations stipulated by laws and regulations;
information directly related to national security and national defense security;
information directly related to public safety, public health and major public interests;
information directly related to criminal investigation, prosecution, trial and execution of judgment;
To protect your or others's life, property and other major legitimate rights and interests, but it is difficult to get your authorization and consent;
The personal information that you have disclosed to the public;
It is necessary for accomplishing the contract according to the requirements of the personal information subject;
Your personal information is collected from the legally publicly disclosed information, such as the legal news reports, government information disclosure and other channels;
necessary for maintaining the safe and stable operation of the software and related services, such as the discovery and disposal of faults of the software and related services;
information necessary for legal news reporting;
Deidentifying the personal information contained in the results when it is necessary for an academic research institution to carry out statistics or academic research institute based on the public interest, and provides the results of academic research or description in the outside world;
Other circumstances as stipulated by laws and regulations.
(a) Ensure the safe and efficient operation of products and services: we may set up Cookies or anonymous identifiers for authentication and security guarantee, so that we can confirm whether you can log in the service safely, or whether you have encountered embezzlement, fraud and other illegal acts. These technologies will also help us improve service efficiency, improve login and response speed;
(b) Help you to get an easier access experience: using such technology can help you avoid repeating the steps and processes of filling in your personal information and entering the search content (example: record search, form filling).
3.2 If your browser allows it, you can manage Cookies through your browser settings (for example, the appropriate data purging operation in the browser Settings function).
4. Entrusted processing, sharing, transfer and public disclosure of personal information
4.1 Entrusted processing
Each functional module of the product and / or service is provided by us independently, and the personal information required for the related functions is also processed by us. If due to the development of new functions and modules to introduce third party partners, we will strictly to the qualification audit, signed strict confidentiality agreement, require them in accordance with our requirements, this policy and any other relevant confidentiality and security measures to handle personal information, at the same time before the third party partners processing your personal information to inform you, and obtain your consent.
4.2.2 Currently, our authorized partners generally include the following types (subject to the stated content):
(a) Advertising and analysis and service partners. We entrust these partners to process information related to advertising coverage and effectiveness, but we do not provide your personally identifiable information, or we de-identify this information so that it does not identify you personally. Such partners may combine the above information with other data they legally access to implement our commissioned advertising services or decision recommendations.
(b) Suppliers, service providers and other partners. When the third party hardware and software / system products or services combined with our products or services to provide you, with your authorization, we may provide the third party suppliers, service providers and other partners with your necessary personal information, in order to provide us with infrastructure technology services, data analysis services, security services, customer service, etc., to improve your use experience.
(c) Related parties or users of the same account system. We have highly consistent data security guarantee measures and management level with our related parties or users of the same account system. In order to improve the security and convenience of your use of products and have a consistent service experience, we will share your personal information among related parties or users of the same account system on the premise of following the legal requirements.
4.3.1 We will not transfer your personal information to any company, organization or individual, except where:
(a) We have gotten your express consent or authorization in advance;
(b) According to the applicable laws and regulations, the requirements of legal procedures, and the mandatory administrative or judicial requirements;
4.3.2 In the event of the foregoing changes, we will continue to protect or require the successor recipient of personal information to continue to protect your personal information in accordance with the laws and regulations and no less than the safety standards required by this Policy, otherwise we will require the successor recipient to obtain your authorized consent.
4.4 Public disclosure
We will not publicly disclose your personal information collected unless we have to comply with laws and regulations or we have obtained your consent. When we disclose your personal information, we will desensitize your information, including content replacement,remove identification, or anonymity, to protect your information security. When we met any applicable law or response to legal procedure requirements must disclose personal information, we will inform you of the purpose of the public disclosure, the type of information and may involve sensitive personal information, and on the basis of ensuring the disclosure and legal legitimate, comply with the minimum necessary principles of relevant laws and regulations for disclosure.
Please understand that in the following circumstances without your consent in advance, in accordance with relevant laws and regulations and national standards, we have to share, transfer and publicly disclose your personal information:
（a）Relataed to our performance of the obligations stipulated by laws and regulations and the competent authorities of the government, or to solve the needs of litigation and disputes;
（b）information directly related to national security and national defense security;
（c）information directly related to public safety, public health and major public interests;
（d）Information directly related to criminal investigation, prosecution, trial and execution of judgment;
（e）For tbhe protection of the life, property or other major legitimate rights and interests of you or others, but it is difficult to get your consent in advance;
（f）The personal information that you have disclosed to the public;
（g）Information disclosed legally publicly, such as legal news reports, government information disclosure and other channels.
5. Storage and protection of personal information
5.1 Storage period
5.1.1 We will keep your personal information within the shortest time necessary to realize the purpose of handling your personal information process, except that you exercise the right to delete, cancel your account or otherwise stipulated by laws and regulations. After the above storage period and we are not asked by laws to continue to process your specific personal information, we will delete your personal information or anonymize it according to the requirements of applicable laws (the anonymized information is no longer to be identified as the personal information). We take appropriate steps to ensure that we process and retain information about you:
(a)The retention period of personal information shall be the shortest time necessary to achieve the purpose;
(b)as required by law, contracts or our statutory obligations;
(c) Only the time necessary for the purpose of collecting and processing the information shall be retained, but it may be extended according to the needs of the contract and the applicable law, and appropriate safeguard measures shall be taken.
5.1.2 If we stop operating this software, we will stop collecting users 'personal information in time, and inform you of the notice of serving the operation one by one or by announcement. After stopping the operation, we will delete users' personal information.
5.2 Safety and protection measures
5.2.1 According to the requirements of relevant laws and regulations, we have appointed the responsible person of personal information protection and the personal information protection work agency. We have also established a data security management system with data as the core and around the data life cycle to improve the security of the whole system from the aspects of organizational construction, system design, personnel management, product technology and other aspects. We have used industry standard security precautions to protect your personal information against unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonable and feasible measures to protect your personal information. For example, we use encryption to secure confidentiality, we use protection mechanisms to prevent malicious attacks, we deploy access control mechanisms to ensure that only authorized people have access to personal information, and we conduct security and privacy training to enhance employee awareness of the importance of protecting personal information. We attach great importance to the security of your personal information, and will do our best to ensure the security of the information you submit, but please understand that the Internet environment is not absolutely safe, and no security measures can be impeccable.
5.2.2 Specifically, to protect your personal information, we take the following measures:
(a) We take reasonable and feasible measures to ensure that the collection of personal information is minimized and that personal information unrelated to the purpose of processing is not collected;
(b) We will use encryption technology to ensure the confidentiality of information transmission and storage. We will use trusted protection mechanisms to prevent malicious attacks on the servers that store the information;
(c) We will deploy access control mechanism to ensure that only authorized people can access personal information, and control the number of authorized people and manage them according to business needs and personnel level;
(d) We will select business partners and service providers, and implement the requirements of personal information protection into the contract, audit, assessment and other activities of both parties;
(e) We will hold security and privacy protection training courses, tests and publicity activities to strengthen employees' awareness of the importance of protecting personal information.
5.2.3 Although we have the responsibility to protect your personal information, you also have the responsibility to keep your login information properly. If you find that your personal information is leaked, please contact us immediately through the contact information provided by this policy, so that we can take appropriate measures.
5.3 Handling measures for safety incidents
5.3.1 We have used safety precautions meeting industry standards, including but not limited to:
(a) We will take feasible technical measures such as encryption, desensitization and de-identification to ensure the security and confidentiality during information storage or transmission.
(b) We will strictly limit the access authority of information, adopt a hierarchical management or approval mechanism, and minimize the scope of necessary personnel to control the accessible information.
(c) We will establish an information security response team and the corresponding system management system, and regularly confirm the protection of personal information and identify the risks.
5.3.2 In case of personal information leakage or other incidents, we will timely inform you or announce you in accordance with the requirements of laws and regulations, and take timely remedial measures. We will also actively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.
5.4 Notification when the product or service stops operation
When our products or services stop our operations, we will notify you in the form of push notifications, announcements, etc., and delete your personal information or anonymize it within a reasonable period of time, unless otherwise stipulated by laws and regulations.
6. Rights and interests of personal information subjects
We attach great importance to the management of your personal information, and try our best to protect your rights to consult, copy, correct, supplement, delete, withdraw consent authorization, cancel account, complain and set privacy functions, so that you have the ability to protect your privacy and information security. The management paths we provide in different versions or operating systems may vary, we take the version subject to reality. If the following operation Settings fail to achieve or cover the rights to consult, copy, delete, correct, withdraw consent to use personal information, cancel account, complain or report that you need, you can also contact us through the contact information of this policy. After verifying your identity, we will provide you with the corresponding services, unless otherwise provided by laws and regulations or otherwise agreed by this policy.
6.1 Copy of personal information
6.1.1 You can copy your personal information through the path query listed in "Query, Access to Personal Information". If you need a copy of your personal information, you can also apply to download your personal information through the path of "My- -privacy Settings- -Personal Information- -Apply for download". In addition, you can also contact us through the contact information published in this policy. After verifying your identity, we will provide you with a copy of your personal information (including basic information and identity information) in our services, except as otherwise stipulated by laws and regulations or otherwise agreed in this policy.
6.2 Correct and supplement personal information
When you find that the personal information we have handled about you is wrong or incomplete, you shall have the right to correct or supplement the wrong or incomplete information. You can correct or supplement your application through the path of "mine" - "head portrait" - "edit materials", or submit your correction or supplementary application to us through feedback and error reporting. You can also contact us through the contact information provided by this policy. After verifying your personal information, we will correct and supplement your personal information in time.
6.3 Delete personal information
6.3.1 You can delete your browsing / collecting / reading history through the "My-History-More" path;
6.3.2 In the following circumstances, you can contact us through the contact information provided by this policy to delete our personal information:
A. If we violate the laws and regulations or agreement to handle your personal information;
B. If our processing purpose has been achieved, cannot be realized, or it is no longer necessary to achieve the processing purpose;
C. If we stop providing products and / or services, or the storage period has expired;
D. If you withdraw your consent;
E. Other circumstances as stipulated by laws and administrative regulations.
6.4 Change or withdrawal of consent
You can change the scope to which you authorize us to continue to collect your personal information or withdraw your consent by deleting the information, turning off the device rights, and closing the personalized recommendation switch (if any). You may also withdraw part or all of our authorization to continue to collect your personal information by canceling your account.
Please understand that each business function requires some basic personal information to complete, where we may not be able to respond to your request to change the scope of authorization. After you withdraw your consent or authorization, we will not be able to continue to provide you with the corresponding services authorized, and we will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the previous processing of personal information based on your authorization in advance.
If you are unable to change or withdraw your authorized consent through the above path, you can contact us through the contact information provided in this policy, and we will review and reply to your request as soon as possible within 15 working days or within the time limit prescribed by laws and regulations.
6.5 Cancel your account
6.5.1 If you are an individual user, you can cancel your account through the path of "My-Set-Log off account".
6.5.2 You know and understand that account cancellation is an irreversible behavior. Once you cancel your insMind account, you will not be able to use all the products and / or services of the insMind account, so please be careful. After your account is cancelled, we will stop providing you with "insMind" all products and / or services, and according to the laws and regulations by anonymous processing your personal information, or delete the personal information related to your account, but the laws, regulations or regulators on the user information storage time otherwise or according to the customer needs for customer data except otherwise processing.
6.7 Responding to your request for rights
6.7.1 Any questions, suggestions, comments and complaints can be submitted by our customer service through the customer service channel, or through "Workplace" - "Help and resource" - "Feedback". In order to ensure safety, we will reply to your request within 15 working days after receiving your application or within the time limit stipulated by laws and regulations. You may also know that we may not be able to respond to your request if:
(a) Related to our performance of the obligations stipulated by laws and regulations;
(b) Those directly related to national security and national defense security;
(c) Those directly related to public safety, public health and major public interests;
(d) directly related to the investigation, prosecution, trial and execution of criminal crimes;
(e) There is sufficient evidence to show that the subject of personal information has subjective malice or abuse of rights;
(f) To protect the major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the subject;
(g) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
(h) Trade secrets are involved.
6.7.2 For your reasonable request, we will not charge in principle, but for repeated requests, we will charge a certain cost depending on the circumstances. We may reject requests that repeat unreasonably, require excessive technical means (e. g., requiring new systems or fundamentally changing existing practices), pose risks to the legitimate rights of others, or are very impractical (e. g., involving backup information stored on tape).
6.8 Exceptions to the exercise of rights
We may not be able to respond to your requests for review, correction, supplement, deletion, replication, portable, withdrawal of consent, knowledge, decision, and more in the following circumstances:
（a）Those directly related to national security and national defense security;
（b）Those directly related to public safety, public health and major public interests;
（c）those directly related to crime investigation, prosecution, trial and execution of judgments;
（d）We have sufficient evidence to show that you have subjective malice or abuse of rights (if your request will endanger public safety and the legitimate rights and interests of others, or your request is beyond the scope covered by general technical means and commercial costs);
（e）Responding to the request of the personal information subject will cause serious damage to the legitimate rights and interests of you or other individuals and organizations;
（f）Trade secrets are involved;
（g）The circumstances otherwise stipulated by laws and administrative regulations.
7. Revision and update of this policy
7.1 In order to provide you with a better service, the Service will be updated and changed from time to time, and we will form part of this Policy and have the effect of the policy. Without your express consent, we will not reduce your rights under the currently in force Policy.
7.3 Material changes referred to in this Policy include, but are not limited to:
(a) Our service model has undergone major changes. Such as the purpose of processing personal information, the type of personal information processed, the way of use of personal information;
(b) We have undergone major changes in terms of our ownership structure and organizational structure. Such as business adjustment, the owner change caused by bankruptcy merger and acquisition;
(c)The main object of external provision, transfer or public disclosure of personal information changes;
(e) Your rights to participate in the processing of personal information and its exercise mode have changed significantly;
(f) We are responsible for handling the changes in the responsible departments, contact methods and complaint channels of personal information security;
(g) The personal information security impact assessment report indicates a high risk.
8. Contact us
8.1 If you have any comments, questions, suggestions or complaints about this policy or personal information protection, or inquiries about handling your personal information, you may contact us by e-mail address:email@example.com
8.2 In order to ensure that we can deal with your problem efficiently and give timely feedback to you, we will process your request after verifying your identity. Usually, we will respond to your question within 15 working days after receipt; if the situation is complicated and requires delay, we will explain to you within 15 working days.
9.1 The policy interpretation and dispute settlement shall be governed by the mainland laws of the People's Republic of China. If any dispute arising from the signing and performance of this policy and our handling of your personal information, both parties shall try to settle it through friendly negotiation; if the negotiation fails, you may appeal to the people's court with jurisdiction in the location of the defendant. If you think that our personal information processing behavior damages your legitimate rights and interests, you can also report to the relevant government departments.
9.2 During the use of our products and / or services, you may access applications and other services linked to third parties, for which such applications and other services may involve situations where you provide specific types of personal information to third parties. We recommend that you before using the such application or services carefully read the applicable terms and conditions (and any relevant privacy statement), to ensure that the full understanding of the rules of use of your personal information to decided whether to use or not. If you have any questions about a specific third party using your personal information, please contact that third party directly.