Whale Personal Information Protection Policy

Update date: June , 2022

Suggested Provisions

Thank you for your interest in Whale products and services (hereinafter referred to as "We"). We respect your concerns about privacy and appreciate your trust and confidence in us. In view of this, Whale has formulated the "Personal Information Protection Policy" (hereinafter referred to as "this Policy"). We remind you: Before using the services of our website, please make sure that you have carefully read and thoroughly understood this policy. We strive to be clear and concise and to use bold text to alert you to the clauses that are significantly relevant to your interests. If you refuse to provide the personal information necessary for particular services, we may not be able to provide you with the products and services you request.

This policy will help you understand the following:

I. Definition
II. Scope of Application
II. Scope of Application
IV. How We Use Personal Information
V. How We Provide, Transfer, and Disclose Your Personal Information
VI. How We Store Personal Information
VII. How We Protect Personal Information
VIII. Your Right to Manage Personal Information
IX. How We Deal with Children's Personal Information
X. How This Policy Is Updated
XI. How to Contact Us
I. Definition

Whale Website: Whale Official website (The domain name:www.meetwhale.com/ and associated domain names)
Whale: Unless otherwise agreed, "Whale" refers to relevant legal entities such as Whale Cloud Technology (Hangzhou) Co., Ltd. that provide you with relevant services and assume corresponding responsibilities, including Whale Cloud Technology (Hangzhou) Co., Ltd., Hangzhou Humpback Whale Technology Co., Ltd., etc.
Affiliate Companies: "Affiliate Companies" means companies directly or indirectly controlled by Whale; or that have direct or indirect control of Whale; or co-control of the same company as Whale with the ability to exert significant influence over it; or a company directly or indirectly controlled by the same company as Whale, including but not limited to parent companies, subsidiaries, etc.
Personal Information: Unless otherwise specifically provided by applicable laws in your region, "personal information" means all kinds of information recorded electronically or otherwise relating to identified or identifiable natural persons, excluding anonymized information.

II. Scope of Application

We believe that your personal information is very important and we attach great importance to your right to privacy. This policy describes how we collect, use, store, provide, transfer, and publish your information. You access or use (a) our website and website resources; (b) 数智空间 products. The Website, the App, and any services we provide in connection with one or more of the above businesses are collectively referred to as the "Services."
This Policy does not apply to how third parties collect, use, disclose or retain information. We recommend that you review the personal information protection policies of these third-party websites or services.

III. How We Collect Personal Information

1. Account Registration
In order to register as a user of our services, you will need to provide your mobile phone number, email address, name, password, and verification code to create or log in to the Platform.

2. Active Users
In order to provide you with the services you choose to use or to guarantee the quality of service and experience, we will collect your online behavior data.

3. Products and Technical Services of 数智空间
In order to provide customers with the product technology of 数智空间, customers and their employees need to provide mobile phone numbers and email addresses to log in and receive operational data, work tasks, approval tasks, customer service consultation, operation, maintenance, and others.

4. Security Services
In order to meet the relevant legal requirements, and to provide you with safe and stable services, to protect you from viruses, Trojans, or other malicious programs and websites, we need to record the service category, method and device brand, device model, device name, device software version information and other daily logs and service-related information in the process of your use of our services.

5. Cookies and Services of Similar Technologies
Cookies and similar device identifiers are technologies commonly used on the Internet. For the proper function of our apps and services, we may use your cookies to make it easy for you to log in or use cookie-dependent services or features.
You have the right to accept or decline cookies. You can decline cookies by changing your browser settings. However, if you decline cookies, you may not be able to log in or use services/functions dependent on cookies.

6. When you use the services related to 数智空间 APP, In order to ensure the implementation of App-related functions and stable operation of applications, we may access the software development kit (SDK) provided by a third party to accomplish relevant goals. Different versions of the third-party SDK will be different, and we will conduct strict security monitoring of the software tool development kit (SDK) for obtaining information from the partner to ensure data security. For more information about the purpose, method, and scope of personal information processed by the SDK, please refer to the SDK Information List.

IV. How We Use Personal Information

1. To accomplish the purposes described in "How We Collect Information" in this Policy.

2. To keep you informed of the status of your use of the services, we will send you service reminders or notifications.

3. Report to the relevant authorities in accordance with laws, regulations, or regulatory requirements.

4. Invite you to participate in customer research related to our services.

V. How We Provide, Transfer, and Disclose Your Personal Information

1. Provide
We do not share your personal information with companies, organizations, and individuals outside whale's jurisdiction, except in the following circumstances:

a) When your explicit consent or authorization have been obtained.

b) When administrative, judicial, and other competent authorities make relevant requests in accordance with relevant laws and regulations.

c) When providing the core functionality of our relevant products and services, including to our affiliates and partners.

d) When based on social public interests in accordance with relevant laws and regulations.

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

a) When your explicit consent or authorization have been obtained.

b) When necessary in accordance with the requirements of laws, regulations, legal procedures, administrative, or judicial compulsion.
In the case of asset transfer, acquisition, merger, reorganization, or bankruptcy liquidation, if the transfer of personal information is involved, we will inform you of the relevant situation and require new companies and organizations holding your personal information to continue to be bound by this policy. We will require the new company or organization to seek your explicit consent again if their stated goals or use of personal information changes.

3. Public
We will not disclose your personal information publicly, except in the following cases:

a) When your explicit consent or authorization have been obtained.

b) Disclosure Based on Law: We may disclose your personal information in the event of a mandatory request by law, legal process, litigation, or competent government authority.

VI. How We Store Personal Information

We will store the personal information collected and generated in China in accordance with laws and regulations. In general, we will not transfer your personal information overseas, unless required to comply with laws and regulations and having obtained your explicit consent. If we transfer outside of our country, we will comply with the relevant country's regulations and seek your consent.
We only keep your personal information for the period necessary to provide Whale products and fulfill their purposes, and strictly comply with the relevant requirements of laws, regulations, and regulatory policies regarding the minimum period of retention.

VII. How We Protect Personal Information

We have used industry-standard security measures to protect your personal information from unauthorized access, disclosure, use, modification, damage, or loss. To ensure the security of your information, we are committed to using a variety of security technologies and supporting management systems to minimize the risk of your information being leaked, damaged, misused, altered, accessed, or disclosed without authorization. For example, information shall be encrypted, transmitted, and stored using network security layer software (SSL); Whale's services will be used to authenticate and firewall, blocking unauthorized and malicious access; a unified role and permission control system shall be established to strictly restrict access to data centers; when transmitting and storing personal information, security measures such as encryption, permission control, de-identification, and anonymization shall be employed.
We have obtained the information security level protection level 3 certification, the ISO/IEC27001/IEC information security management system certification, the ISO/IEC 27017 information security control measures certification, and the ISO9000 quality management system certification.
Our data security capabilities: We have a personal information protection responsibility unit that conducts personal information security impact assessments for personal information collection, use, provision, commissioning, etc. Meanwhile, we have established an internal control system to handle tasks, including but not limited to creating emergency response plans for personal information security incidents, organizing emergency response trainings and emergency drills on a regular basis, managing and controlling permissions and behaviors of employees with access to personal information, training on laws, regulations, and practices related to information security protection, and organizing examinations on security for all employees.
In the case of an unfortunate occurrence of a personal information security incident, we will promptly inform you in accordance with laws and regulations on the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and suggestions for remedial measures to help you prevent and reduce risks independently. We will inform you of such information by email, letter, telephone, and/or push notification, and when it becomes difficult to notify each personal information subject individually, we will properly and effectively issue a public notice.
The Internet is never completely secure, but we will endeavor to ensure and warrant the security of any information you send to us. If our physical, technical, or administrative protection facilities are damaged, resulting in unauthorized access, disclosure, alteration, or destruction of information, resulting in damage to your legitimate rights and interests, we will bear the corresponding legal responsibility. At the same time, we will also take the initiative to report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.
Please be sure to take good care of your service login and other identity elements. When you use our services, we will identify you with your login name and other identity factors. Once you leak the above information, you may suffer from losses and other adverse impacts. If you find that your login name and/or other identity factors may have been leaked, please contact us immediately, so that we can take appropriate measures to avoid or reduce related losses.

VIII. Your Right to Manage Personal Information

According to relevant laws, regulations, and standards in China, we ensure the following rights to your personal information:

1. Access or correction of personal information
You have the right to access your personal information, except in exceptional circumstances stipulated by laws and regulations. If you want access to your data, you can log in to the platform and do so. If you are unable to access and correct your personal information, you may contact us at any time through the feedback channels mentioned in this Policy and we will provide support.

2. Delete Personal Information
Under the following circumstances, you can request deletion of your personal information:
a) If we process personal information in violation of laws and regulations,
b) If we collect and use your personal information without your consent,
c)如果我们处理个人信息的行为违反了与您的约定;
d) If you have deactivated your account, or
e) If we terminate Services and Operations.

3. Change the scope of the authorized consent
Each business function requires some basic personal information to be completed. When it comes to the collection and use of additional personal information, you can give or revoke your consent at any time. After you revoke your consent, we will stop processing the relevant personal information. However, your revocation does not affect any previous personal information handling under your authorization.

4. Close Your Account
You can de-register an account at any time. We will stop providing the products and services to you and delete your personal information as you request unless otherwise specified by laws and regulations. If you are unable to process your deactivation from the client-side, you may feel free to contact us using the feedback options provided in this Policy.
In the following cases, we will not be able to respond to your request:
a) If it is related to the fulfillment of obligations under laws and regulations by personal information processors,
b) If it is directly related to national security and national defense security,
c) If it is directly related to public safety, public health, and major public interests,
d) If it is directly related to a criminal investigation, prosecution, trial, or judicial enforcement,
e) If the personal information processor has sufficient evidence that the personal information subject harbors subjective malice and/or abuse of others' rights,
f) If it is to protect the personal information subject's or other person's life, property, and other major legitimate rights and interests, and it is difficult to obtain their consent,
g) If responding to the personal information subject's request will cause the lawful rights and interests of the personal information subject or other individuals or organizations to be seriously harmed, or
h) If it involves commercial secrets.

IX. How We Deal with Children's Personal Information

Our products or services are mainly for adult and corporate customers and are limited by existing technologies and business models. If we collect relevant personal information on a child without the consent of a parent or guardian, please contact us as soon as possible to delete. Children’s personal information that is collected with a parent's consent will only be used or publicly disclosed when it is permitted by laws and explicitly consented to by their parents or guardians, or when is essential to protecting the children.

X. How This Policy Is Updated

We may revise or change the Personal Information Protection Policy and other products or services from time to time, and we will not reduce your current rights without your explicit consent. We will post any changes to this policy on this page. If changes are significant, we will provide a more prominent notice (including, for certain services, email notification of change details).

XI. How to Contact Us

If you have any questions, comments, suggestions, complaints or reports about this Personal Information Protection Policy, please contact us at the following channels: 400-668-9930; email: hello@whale.im We will review the issue as soon as possible and respond within 15 working days of receiving your request. We have designated personal information protection specialists, and you can get in touch with them through email or mail. Our address is: 18F, Block H, Huanglong Vanke Center, Xihu District, Hangzhou, Zhejiang.

To communicate with our Data Protection Officer, please email dpo@whale.im