WESCAUT

Promulgation Date: 01.03.2021
Effective Date: 01.03.2021

Vauman Limited respects and protects the privacy of everyone, especially valuing the protection of your privacy.

Vauman Limited（registered address: Unit G, 15/F, TAL Building, 49 Austin Road, Kowloon, Hong Kong；contact information：email: info@wescaut.com；hereinafter referred to as “Vauman Limited” or “we”）attaches great importance to the protection of your privacy. In order to remain the normal operation of Vauman Limited’s APP (hereinafter referred to as the "Platform"), we will, in accordance with this privacy policy (hereinafter referred to as the "Policy"), collect, store, use and share with external parties your personal information, for the purpose of providing you with our product and/or our services (hereinafter referred to as the "Services"). This Policy aims to inform you about what personal information we will collect and how we will use it.

This Policy is closely related to your use of our Services. You are advised to carefully read and understand the entire content of this Policy and then make your choice regarding whether to agree to it or not. If you do not agree with the terms of our Service Agreement or this Policy, please do not use our Services or provide us with any of your personal information.

This Policy will help you to understand the following information:
1. Scope of application of this policy
2. How we collect and use your personal information
3. How we use Cookies and similar technologies
4. How we share, transfer and publicly disclose your personal information
5. Protection of your personal information
6. Storage of your personal information
7. Your rights to your personal information
8. How we handle children's personal information
9. How this Policy will be updated
10. Contact us

1
Scope of application of this policy
This Policy applies to all APPs, websites, products or services operated or provided by us and with a link to this Policy, as well as our activities of collection, storage, transfer, sharing, disclosure and processing of your personal information involved in your use of our Services as defined below.

This Policy does not apply to any other third-party websites or APPs that our Platform may link or redirect to, and we assume no responsibility for such third-party platforms. When you access such platforms or use services provided by third parties, please carefully review the privacy policies developed and published by them. Please be informed that any exposure of your information to third parties will be at your own risk. You shall carefully consider the risk of privacy protection.We have no control over the actions of such third parties and shall not be responsible for any platform or services provided by the third parties.

2
How we collect and use your personal information
Adhering to the principles of legitimacy, lawfulness and necessity, we shall collect and use your personal information that is actively provided by you or generated in connection with your use of our Platform and/or Services for the purposes stated in this Policy. If the collected information shall be used by any means unspecified in this Policy, or for other special purposes, we shall inform you in a reasonable manner and seek your prior consent.

2.1
Circumstances under which you must authorize us to collect and use your personal information
The following basic functions are indispensable to our Services. We have to collect and use the following personal information of yours to provide these functions. If you do not agree to the collection of such information, you will not be able to enjoy our Services. Such functions and services include:

1)
Account registration
As our Services are account-based, you shall provide your email address and account name for registration in order to become a formal user and enjoy our Services.

Other personal information such as your company name, business type, job title, country, address, photo and your accounts on other platforms may be provided to supplement your account information. If you choose not to provide such information, you can still use the basic functions of our Platform to view supplier and product information.

2)
Analysis of browsing activities
One of the basic functions of the Platform is to provide the users who publish supplier and product information with analysis reports of how their posts are viewed within the Platform. In order to provide this function, we will collect and analyze relevant information generated from your browsing activities within the Platform, including your browsing and search history, device information and service log.

Please note that the device information and service log alone cannot be used to identify a natural person’s identity. If we combine such information with other information for the purpose of identifying a particular natural person, or combine such information with other personal information of a natural person, then such device information and service log will be deemed as personal information during the combination. Unless we have obtained your consent or otherwise permitted by laws and administrative regulations, we will anonymize or de-identify such information.

We will share the analysis reports of your browsing activities with the users who publish supplier and product information. Such reports will not contain your personal information, unless we have obtained your consent or otherwise permitted by laws and administrative regulations.

3)
Information publishing and communication within the Platform
Information publishing and communication within the Platform is the key function of this Platform. You may choose to publish supplier and product information based on your own needs. When you use this function, you will need to provide us with the information of your company and product, as well as your contact information and the contact’s Platform account. You will also need to provide us with the content of your communication.

This function aims to provide a channel for enterprises to display the information of their products and themselves. You shall avoid publishing any personal information of yourself or others when using this function. If you provide your personal information to others when you communicate within the Platform, we are not able to and will not assume liability for the use of your personal information by others.

4)
Search function
When you use the search function provided by the Platform, we collect information about the keywords of your query and other information and content details that you browse or request while using the Platform. Such keywords information alone normally cannot be used to identify your identity and thus is not considered as your personal information and not be bound by this Policy. It shall only be considered as your personal information when it is combined with other information about you and then can be used to identify your identity. In this case and during such combination, we will process and protect the keywords information as well as your search records in accordance with this Policy.

5)
Notification
We will record the information when you follow certain suppliers or products. We will send you a notification when there is an update regarding such suppliers or products. If you do not wish to receive the notification anymore, you may unfollow at any time.

6)
Customer service and dispute settlement
In order to ensure the security of your account and the system, you will be required to provide us with your personal information to verify your identity when you contact us or apply for resolving any dispute. We may keep records of our communications, correspondence, phone calls and other related contents in order to contact you more conveniently, to resolve your problem more efficiently, and to better record the solutions and results of relevant problems.

2.2
You may choose whether or not to authorize us to collect and use your personal information
In order to receive the following extended functions of our Services, you may choose to authorize us to collect and use the following personal information. If you refuse to give your consent, you will not be able to use the relevant extended functions, but your normal use of the basic functions will not be impeded.

Marketing:We will send advertisements to you for marketing purposes after we obtain your consent. To withdraw your consent, you may contact us via the channel provided by the advertisements or under "10. Contact us" in this Policy.

3
How we use Cookies and similar technologies
When you access the Platform, our partners and us will use cookies or other similar technologies to analyze your preferences, manage the Platform, track your browsing activity on the Platform and collect information about the overall user base.

Cookies are small data files that are managed and stored in your local system browser or other applications. We will use session information and ongoing Cookies information to identify your computer when we interact with you and analyze your behavior when you access the Platform. Most browsers give you the option to agree to Cookies or not, and will alert you every time you send a message. If you refuse to use Cookies, you may not be able to enjoy our Services in their entirety.

4
How we share, transfer and publicly disclose your personal information

4.1
Sharing
Your personal information will not be shared with any external company, organization or individual, unless under such circumstances:

1)
When prior consent is obtained from you:Your personal information will be shared with other parties when your consent is expressly given.
2)
When it is legally required:Your personal information will be shared in accordance with applicable laws and regulations, legal procedures, mandatory government orders or judicial rulings.
3)
When your personal information is shared with our affiliates:Your personal information may be shared among our affiliates. We will share your personal information for the purpose stated in this Policy and share only the necessary information. If our affiliates change the purpose and the way of personal information processing, we will seek your consent again.
4)
When your personal information is shared with service providers and our authorized partners:We may entrust our authorized partners to provide certain services or perform our obligations on behalf of us. Your personal information shall be shared only for the purposes which are legitimate, proper, necessary, specific, and expressly stated in this Policy. Our authorized partners will access the information which is necessary to perform their duties, and they will not utilize such information for any other purpose.

Currently, our service providers and authorized partners include:

-
Authorized partners for advertising and analysis services
Unless your prior consent is given, your personal information will not be shared with our partners for advertising and analytics. We may entrust such partners to process information related to the effectiveness and the reach of our advertisements. However, your personal information will not be shared, or will only be shared after being anonymized so that your personal identity will not be identified. Such partners may combine the above information with other data which is lawfully obtained by themselves, in order to provide advertising services or implement decisions and suggestions as entrusted by us.

-
Vendors, service providers and other partners
We will provide information to vendors, service providers and other partners who offer their support to our business, including entrusted technical infrastructure services. Currently, such partners include Vauman Shanghai. Our information sharing serves to realize the basic function of our Services.

5)
Management of SDK/other third-party plug-in
The Platform will be connected with third-party plug-in products to provide you with more professional and secure services (e.g. SDK, API).

Currently, we deploy the following third-party plugs-in in our services (both Android and iOS):

Name of the SDK: firebase SDK

•
Relevant services:
Information pushing
•
Collect types of personal information:
Personal common device information (MAC address, IMEI, serial number)
•
Link to privacy policy of the SDK:
https://firebase.google.com/docs/android/setup?hl=zh-cn

Name of the SDK: pushy SDK

•
Relevant services:
Information pushing
•
Collect types of personal information:
Personal common device information (MAC address, IMEI, serial number)
•
Link to privacy policy of the SDK:
https://pushy.me/docs

Name of the SDK: fresco SDK

•
Relevant services:
Information sharing to Wechat
•
Collect types of personal information:
No
•
Link to privacy policy of the SDK:
https://www.fresco-cn.org/docs/

Name of the SDK: Wechat Sharing SDK

•
Relevant services:
Image processing
•
Collect types of personal information:
No
•
Link to privacy policy of the SDK:
https://developers.weixin.qq.com/doc/oplatform/Mobile_App/Share_and_Favorites/Android.html

The aforementioned plugs-in will collect your personal information in relation to the platform and/or services. We will only provide the personal information API to the aforementioned third-party plugs-in when you consent to the activation of relevant functions, or when you voluntarily use the relevant functions and are provided with sufficient notice.

4.2
Transfer
We will not transfer your personal information to any company, organization, or individual except under the following circumstances:

1)
Transfer with explicit consent: after acquiring your explicit consent, we will transfer your personal information to other parties.
2)
When the transfer of personal information is involved in a(n) merger, acquisition or bankruptcy liquidation, we will require the new company or organization to which your personal information is transferred to continue to be bound by this Policy, otherwise we will require the new company or organization to seek your consent again.

4.3
Public Disclosure
We will only publicly disclose your personal information under the following circumstances:

1)
After we obtain your explicit consent.
2)
Statutory disclosure: we might publicly disclose your personal information as stipulated by laws, regulations or the mandatory requirements of government agencies.

5
Protection of your personal information
We have employed security protection measures according to industry standards, aiming to protect your personal information, to prevent unauthorized access to, disclosure, use, modification, damage or loss of data. We will take every practical measure for the protection of your personal information. Please understand that your personal information may still be disclosed, destroyed or lost due to various malicious attacks that are unforeseeable or indefensible by existing technology, even if we do our best to take the above measures. If your legal rights and benefits are adversely affected due to the unauthorized access to, disclosure, tampering or damage of your personal information resulting from the damage of our physical, technical or management protection facilities, we will assume legal liabilities accordingly. We will notify you of any information security incident involving your personal information as required by applicable laws.

6
Storage of your personal information
Your information will be stored on servers of us or our service providers located in mainland China.

We shall keep your personal information for the shortest time which is necessary to achieve the purposes described under this Policy, unless otherwise required or prohibited by applicable laws.

7
Your rights to your personal information
When we take various measures to protect the accuracy and integrity of your personal information, we also expect you to provide accurate and complete personal information when interacting with us.

7.1
We will safeguard you to exercise the following rights to your personal information:

1)
Access your personal information
You have the right to access your personal information, unless laws and regulations specify otherwise. If you wish to access your data, you can do so by visiting the "Account" section of the Platform and accessing your account information and browsing records.

If you cannot access the personal information via the method above, you may contact us at any time via the contact details provided under "10. Contact us". We will respond to your access request within 15 working days.

2)
Rectify your personal information
When you find a mistake in your information that we are processing, you have the right to ask us to rectify it. You may raise your request by contacting us via the contact details provided under "10. Contact us".

3)
Delete your personal information
You may request us to delete your personal information if:

-
our processing of your personal information violates laws or regulations,
-
we collect and use your personal information without obtaining your consent,
-
our processing of your personal information breaches our agreement with you,
-
you no longer use our products or Services, or if you have cancelled your account,
-
we no longer provide you with our Services.

You may contact us with your request via the contact details provided under "10. Contact us".

If we decide to respond to your request of deleting your personal information, at the same time, we will also notify the entities who have obtained your personal information from us and request them to delete it in a timely manner, unless otherwise required by laws and regulations, or they have obtained your consent independently.

The corresponding information may not be immediately deleted from our backup system when you delete information from our Services, but we will delete such information when the backup system is updated.

4)
Change the scope of your consent
Each business function needs some basic personal information to be completed (see Article 2). As to the collection and use of additional personal information, you can give or withdraw your consent at any time.

You may contact us with your request via the contact details provided under "10. Contact us".

When you withdraw your consent, we will stop processing the corresponding personal information. However, your withdrawal of consent will not affect the processing of personal information carried out based on your prior consent. After the withdrawal of your consent, we will not be able to provide you with Services that require the processing of your personal information.

5)
De-register
You can de-register at any time by visiting “Account” – “Your Account” – “Delete account”.

After de-registration, we will stop providing you with any product and service and delete your personal information according to your request, unless laws and regulations specify otherwise.

6)
Obtain a copy of your personal information
You have the right to obtain a copy of your personal information. You may contact us with your request via the contact details provided under "10. Contact us".

7)
Restrict automated decision-making by the information system
For some business functions, decisions are made solely based on an automated decision-making mechanism such as the information system and algorithm. If these decisions significantly affect your legal rights and interests, you have the right to ask for our explanation and we will make proper remedies. You can contact us at any time via the contact details provided under "10. Contact us".

7.2
Respond to your abovementioned request
For security, you might be required to submit written requests or prove your identity by other means. We might ask you to verify your identity before handling your request.

If you fail to exercise your rights by means provided above, you may contact us at any time via the contact details provided under "10. Contact us". We will respond within 15 working days.

We will not charge you for your reasonable requests in principle. However, a fee to reflect the cost will be imposed as appropriate on repeated requests beyond the reasonable scope. As for repeated requests that are groundless and need excessive technological means (e.g. developing a new system or fundamentally changing the current practices) to fulfill, bring about risks to others’ legitimate rights and interests, or are downright impractical (e.g. involving information stored on a backup disk), we might reject.

We will not be able to respond to your request under the following circumstances:

-
related to our compliance with the obligations under the laws and regulations,
-
directly related to national security or national defense,
-
directly related to public safety, public health, or major public interests,
-
directly related to a criminal investigation, prosecution, trial or enforcement of court decisions, etc.,
-
there is sufficient evidence that you have subjective malice or abuse of rights,
-
for the purpose of safeguarding your life, property and other important legal rights and interests or those of other individuals but it is difficult to obtain consent,
-
responding to your request will cause serious harm to your legitimate rights and interests, or those of other individuals or organizations,
-
involving trade secrets.

8
How we handle children's personal information
We provide Services to adults via this Platform. If you are not yet an adult, please cease to use our Platform. If you are aware that we process the personal information of a minor, please contact us in time so that we can delete such information.

9
How this Policy will be updated
This Policy may be changed. We will not reduce any of your rights under this Policy without your explicit consent. We will release any change to the Policy in the Platform. In the event where we update the Policy, we will issue the updated version with the date of the last change. You can access any time the updated Policy within this Platform. If you continue to use our Services after the announcement of the change of this Policy, it will be deemed as you have fully read, understood and accepted the revised privacy policy and will use the Services in accordance with the revised privacy policy.

For major changes, we will provide a more conspicuous notice (including, for certain services, notices via email that explains the details of the changes to the Policy) and seek your consent.

The major changes to this Policy include but are not limited to:

-
major changes in our service mode, e.g. the purpose of processing personal information, the type of processed personal information, and how personal information is used,
-
major changes in our ownership structure, organizational structure, e.g. the change of owners due to business adjustments, such as a(n) merger, acquisition, or bankruptcy,
-
changes of the party which personal information is publicly disclosed to, shared with, or transferred to,
-
changes in your rights involved in personal information processing and in how you exercise such rights,
-
changes of our responsible department(s), contacts and complaint channels for personal information protection,
-
when a personal information impact assessment report indicates high risks.

10
Contact us
If you have any doubt or comment regarding our Services or this Policy, or if you would like to exercise your right to access, rectify or delete personal information, or if you want to lodge a complaint regarding privacy protection, you can contact us by sending an email to info@wescaut.com.

Generally, we will reply to you in 15 working days.