CAftrade Privacy Policy

Update date: November 16, 2021

Availability date: November 23, 2021


Introduction

Welcome to the CAftrade!

We attach great importance to the protection of users' privacy and personal information. When you use our products and/or services, we may collect and use your relevant information. Through this CAftrade Privacy Policy (hereinafter referred to as "Policy"), we hope to explain to you how we collect, use, store, share and transfer this information when you use our products and/or services, as well as the ways we provide you to access, update, delete and protect this information.

This Policy will help you understand the following:

1. How we collect and use your personal information

2. How we use Cookies and similar technologies

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

4. How we protect and store your personal information

5. How to manage your personal information

6. The protection of personal information for minors

7. Notice and revision of this Policy

8. How to contact us

9. Other

This Policy is closely related to various business functions (hereinafter referred to as "Our products and/or services") included in CAftrade and related services you use. We hope that you can carefully read and confirm that you have fully understood the contents stated in this Policy before using our products and/or services and that you can make the choices you think appropriate according to the guidelines of this Policy. The terms involved in this Policy are stated as concisely as possible and links to further instructions are provided for better understanding.

Please note that this Policy applies to products or services provided by CAftrade. If the products or services provided by CAftrade are used in the products or services of our affiliated companies without independent Policy, this Policy is also applicable to these products or services.


1.      How we collect and use your personal information

Personal information refers to all kinds of information recorded electronically or by other means that can identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information. Sensitive personal information is personal information that, if leaked, illegally provided or misused, could endanger the safety of persons and property, and could easily lead to damage to a person's reputation, physical or mental health or discriminatory treatment, etc. (we will prominently identify the sensitive personal information involved in this Policy in BOLD).

In accordance with the principles of legitimacy, legality and necessity, we will collect and use your personal information actively offered or generated due to the use of products and/or services and your relevant personal information obtained from a third party for the purposes described below in this Policy. If we want to use your personal information for purposes other than those set out in this Policy, or to use information collected for a specific purpose, we will inform you in a reasonable manner and obtain your consent again prior to such use.

The following is the circumstances under which you must authorize us to collect and use your personal information: our products and/or services include certain core functions that are necessary to enable online posting and security, and we may collect, store and use the following information about you to enable these functions. If you do not provide such information, you will not be able to take advantage of the products and/or services we offer. These functions include:

1.1.  Realize the functions necessary to obtain and publish information online

1.1.1.     Account registration, login and verification

When you sign up for the CAftrade and related services, you will need to provide us with at least your intended account name, password, your mobile number, and Email address (for E-mail verification), and we will verify your identity by sending you an SMS verification code or via E-mail. Your account name is your default nickname, and you may change and add your nickname, gender, birthday, interests, and your real name verification-related information, all of which are part of your “account information”. Your additional account information will help us provide you with personalized information recommendations and a better user experience, but if you do not provide such additional information, it will not affect your access to the basic functions of online information browsing.

Once you have successfully registered for a CAftrade account, you can use it to log in to the CAftrade. You will need to provide us with your CAftrade account information when logging in. If you do not provide such information, you will not be able to log in, access or post any information on the CAftrade platform; while you are allowed to use the browsing and search functions and we will not collect your personal information mentioned above.

1.1.2.     Account real name identification

When you use the function or service that require identity verification, according to the relevant laws and regulations, you may need to provide your real identity information (real name, valid personal ID number, phone number) to complete the real name identification. In particular and where necessary for security reasons, we may verify your identity based on the information you provide in order to ensure that we are providing services to you personally. For example, we will verify your identity through “face recognition”. This information is personally sensitive and you may refuse to provide it. By doing so, though the normal use of other features and services won’t be affected, you may not be able to access the relevant services.

1.1.3.     Account/password recovery

You can retrieve your account through the account/password recovery function. To protect your account security, we may require you to enter relevant information for verification when retrieving your account, and may verify your identity through real name identification, face recognition, etc., if necessary.

1.2.  Presentation and view of the information on the platform

1.2.1.     CAftrade and its related services may recommend information you are interested in and we may collect log information necessary for this function. The log information used for information presentation includes:

(a). The information of your operation and usage behavior: click, follow, favorite, search, query, browse, download, share and transaction;

(b). Information you actively provide: feedback, post, like, comment, edit, gender, birthday, region, introduction;

(c). Geographic location information: accurate geographic location information obtained from sensors such as GPS, WLAN access point, Bluetooth, base station, etc., and approximate geographic location information obtained through network location information (such as base station, IP and WLAN);

(d). When you use CAftrade and related services, in order to ensure the consistency of the services you receive and facilitate unified management, you may share the above log information after de-identification with these functions.

1.2.2.     GPS geographic location is sensitive personal information, if you refuse to provide it, we will not provide you with information based on GPS information. And it will not affect the normal use of CAftrade and its related services.

1.2.3.     We will show and recommend local relevant information in your area to you based on the city corresponding to the approximate geographical location information.

1.2.4.     The above information collected and used by us will be de-identified. The data analysis only corresponds to specific codes that cannot be directly linked to your identity, and will not be linked to your real identity.

1.3.  Information publishing and interaction

1.3.1.     Information publishing

1.3.1.1.    We will collect information that you post, such as your published content, comments, questions or answers, and display your nickname, avatar and published content.

1.3.1.2.    If you need to use the functions of uploading pictures, audio and video, scanning codes, storing application-related information on your mobile phone, or you need to communicate directly with other users and customer service personnel (e.g., voice and text communication, telephone communication, etc.), we will ask you to authorize your mobile phone's memory to read, camera, photo album (storage space), photos, recording, telephone and other permissions. If you refuse to authorize, you will not be able to use such functions, but it will not affect your normal use of other functions of CAftrade software and related services.

1.3.1.3.    When you post a message and choose to display your location, we will ask you to authorize geolocation permissions and collect location information related to this service. If you refuse to provide accurate geolocation information, you will not be able to use this fuction, but it will not affect your use of other functions of CAftrade and its related services.

1.3.1.4.    Please note that your publicly posted information may involve personal information of you or others. If your publicly posted information contains personal information of others, before uploading and posting, you need to ensure that the use is permitted by laws and regulations or has been legally authorized.

1.3.1.5.    If you are an individual user, you need real name identification according to laws, regulations and security requirements when using the Job INFOS module. We will verify your identity through "face recognition". In the process of real name identification, the third party certification authority needs you to provide real name, valid personal ID number and facial feature information. This information is personally sensitive and you may refuse to provide it without affecting your use of other functions of CAftrade and its related services. This information will only be used for the purpose of real name identification and as required by law, and will not be used for any other purpose without your express authorization.

1.3.1.6.    The information collected by us when users use our products or services, such as the information published by other users, may contain some of your information (e.g., information related to you in comments, messages, published graphics, audio and video).

1.3.1.7.    We attach great importance to the user experience. In order to improve the upload speed of content, enrich the publishing function and optimize the experience, we may temporarily load the content to be published to the server before clicking "Save draft"/"Publish" to confirm. If the uploading failed for cancellation or other reasons, we will delete relevant content immediately.

1.3.1.8.    In order to facilitate users to view and edit drafts on other devices and optimize the user experience, when you confirm saving your edited content to the draft box, you understand, confirm and agree that the content of the draft box can be loaded into the server. During use, you can also choose to close at any time. If you want to close the Save to Cloud function, you can close it in System Settings, or if the saving failed for cancellation or other reasons, your content will not be stored in the cloud, but it will not affect the saving of drafts locally. Please rest assured that the content you stored in the cloud will be stored with strong encryption, and no one has the right to illegally access, view, obtain, use and disclose it.

1.3.1.9.    When you participate adaptation campaign of CAftrade and its related services, you may be required to turn on the physical activity identification permission; if you refuse to do so, you will only be unable to use the corresponding functions of the activity, but it will not affect your normal use of other functions of CAftrade and its related services.

1.3.1.10.  Allow this App to catch exception. When crash occurred in this APP, the exception and related device information (user’s personal information not included) will be uploaded to the analysis background. From this, we have introduced SDKs, such as com.tencent.bugly (Bugly; Tencent Bugly), to quickly find, collect and repair exceptions so that user feedback could be followed up timely.

1.3.2.     Interaction

1.3.2.1.    When you actively follow the accounts, groups, activities and topics you are interested in and interact with them, or browse, comment, collect, like or share the content, we will collect the information of the accounts you follow and show you the content posted by the accounts you follow.

1.3.2.2.    When you share or receive shared information and participate in activities, we need to access your clipboard and read the passphrase, sharing code and link contained therein to realize functions or services such as jump, sharing and activity linkage.

1.3.3.     Notifications

You acknowledge and agree that for your contact information (e.g. contact number) provided by you in the process of using products and/or services, we may send multiple kinds of notifications to one or more of them during operation for user message notification, identity authentication, security authentication, user experience research, dispute settlement, etc; in addition, we may also provide you with the use of commercial information such as services, functions or activities you may be interested in by means of SMS and calls; but please rest assured that if you don't want to accept these information, you may unsubscribe through the unsubscribe method provided in the mobile phone SMS, or you may contact us directly to unsubscribe.

1.3.4.     User feedback and service

1.3.4.1.    Clients and problems: In order to facilitate contact with you, help you solve problems as soon as possible or record the solutions and results of relevant problems, we may keep records of your correspondence/calls with us and related content (including account information, feedback information, order information, other information you provide to prove relevant facts or contact information you left). We may use your account information and order information if you make inquiries, complaints or suggestions regarding a specific order.

1.3.4.2.    When you complain about others or are complained by others, in order to protect the legitimate rights and interests of you and others, we may provide your account/identity information, contact information and complaint-related contents to relevant departments for the purpose of timely resolution of complaints and disputes, except where such provision is expressly prohibited by law or regulation.

1.3.4.3.    If you use CAftrade and related parties and partners of its related service through our products or services to make a complaint, in order to facilitate the product/service provider to effectively contact you and deal with your complaint in time, you agree that we can obtain the personal information provided during your complaint from the related parties and partners of relevant service and synchronize it with the corresponding product/service provider.

1.3.4.4.    Questionnaire: in order to provide services and improve service quality, we may also use your other information, including the relevant information you provided when you contacted the customer service and the questionnaire reply information you sent to us when you participated in the questionnaire; if you don't want to, you can also refuse to provide information about your questionnaire participation.

1.4.  Search

1.4.1.     When you use the search service, we will collect your search keyword information, log information records and analyze them in order to show you more relevant search results. Search results, popular searches, and related searches may be displayed through your search/browsing, personal page information, log information, etc.

1.4.2.     We may also record information that you provide, form or retain while using our services, such as information you submit when you enter query terms, click on historical terms, prompt terms, relevant links, or filter search ranges, time frames, or when you participate in search operations when using the search. You have the right to refuse to provide such information, but this may result in your inability to use a particular service or function, or to achieve the intended results of the relevant service.

1.4.3.     The search results will include information from CAftrade and its related services and from third party websites, and your information may be collected by third party websites when you access them.

1.4.4.     In order to provide efficient search services, some signing information will be temporarily stored in your local storage device, and can show you the content of search results and search history.

1.5.  Purchase membership and related service

When you check out the products in your shopping cart, CAftrade and related services system will generate an order for the products you have purchased. In particular, you need to check whether the membership service you have ordered is correct. The service is effective upon your order and cannot be returned, so please check the order information carefully to ensure that it is correct; if you need invoice, the relevant information and e-mail for receiving the invoice are also required.

1.6.  Payment function

After you place an order, you can choose the payment service provided by the affiliated party of CAftrade or the third-party payment institutions cooperating with CAftrade (including Alipay Pay, WeChat Pay, PayPal and other payment channels, hereinafter referred to as "payment institutions"). Your personal information won't be collected in the course of payment, but we need to share with these payment institutions your CAftrade order number and transaction amount information, including your bank card number, expiration date, repayment amount and other necessary information for card payment to enable them to confirm your payment instructions and complete the payment. "Associated Party" means any company, institution and the legal representative of such company or institution that a party controls, is controlled by, or is under common control with, now or in the future. "Control" means the ability, directly or indirectly, to influence the management of the company referred to, whether through ownership, voting shares, contracts or other means as determined by the judiciary authorities.

1.7.  Customer service and after-sales functions

Our telephone client service and after-sales functions may use your account information and order information.

To ensure the security of your account, our customer service will use your account information to verify your identity. When you need us to provide customer service and after-sales service related to your order information, we will query your order information. You may provide other information than the above information when communicating with our customer service personnel.

1.8.  Operation and security

1.8.1.     Operation and security

We are committed to providing you a safe and reliable product and environment, and our core goal is to provide quality, efficient and reliable service and information.

1.8.2.     Equipment information and log information

1.8.2.1.    In order to ensure the software service and your account security, service operation quality and efficiency, 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, base station, software version number, network access method, type, status, network quality data, operation, usage and service logs. We may associate your device information or phone number with your CAftrade and related service account.

1.8.2.2.    In order to prevent malicious programs, safeguard the service security and improve the viewing experience, we may collect information about installed applications or running processes, overall application operation, usage and frequency, application crashes, overall installation and usage, performance data and application sources.

1.8.2.3.    In order to analyze statistical indicators such as app additions, activations, retention, performance, etc., we may bring up clipboard for attribution analysis of relevant statistics, please rest assured that will not collect your private information.

1.8.2.4.    We may use your account information, device information, service log information, and information that our associated company and partners are authorized by you or legally allowed to share for the purpose of determining account security, application launch activation and activity, identity verification, detection and prevention of security incidents.

1.9.  Changes in the purpose of collecting and using personal information

Please acknowledge that as our business evolves, we may make changes to the functions of the CAftrade and related services! The services provided may be adjusted or changed. In principle, when a new function or service is related to the function or service we currently provide, the personal information collected and used will be directly or reasonably related to the original purpose of processing. In the case that there is no direct or reasonable connection with the original processing purpose, if we collect and use your personal information, and again, in accordance with the requirements of laws and regulations and national standards, we will inform you separately by means of page prompts, interaction processes, agreement confirmation in order to obtain your consent.

1.10.          Exceptions

Please acknowledge that, in accordance with laws, regulations and relevant national norms, we are not required to obtain your prior authorized consent for the collection and use of your personal information in the following cases:

(a). in connection with the performance of our obligations under laws and regulations;

(b). directly related to national security and national defense security;

(c). directly related to public safety, public health, and significant public interests;

(d). directly related to criminal investigation, prosecution, trial and execution of judgments, etc.;

(e). for the purpose of safeguarding your or others' life, property and other significant legitimate rights and interests but for which it is difficult to obtain your authorized consent;

(f). personal information that you disclose to the public on your own;

(g). necessary for the conclusion and performance of a contract at the request of the subject of the personal information;

(h). where your personal information is collected from legitimate public disclosures, such as legitimate news reports, government information disclosure and other channels;

(i). necessary for maintaining the safe and stable operation of the software and related services, such as the detection and disposal of software and related services failures;

(j). necessary for conducting legitimate news reporting;

(k). for academic research institutions, necessary for conducting statistical or academic research in the public interest; and when the results of academic research or description are provided externally, the personal information relevant will be de-identified;

(l). Other circumstances as stipulated by laws and regulations.

In particular, you are reminded that if the information cannot be identified to your personal identity alone or in combination with other information, it is not your personal information in the legal sense; when your information can be identified to your personal identity alone or in combination with other information or when we use data that cannot be linked to any specific personal information in combination with your other personal information, such information during usage will be treated and protected as your personal information in accordance with this Policy.


2.      How we use Cookies and similar technologies

2.1.  Use of Cookies

2.1.1.     To personalize your online experience and make it easier for you to access. We may send one or more small data files called Cookies to your computer or mobile device. The Cookie assigned to you is unique and can only be read by the Web Server in the domain that issued the Cookie to you. We send cookies to you to simplify your repeated login steps, store data such as your information viewing preferences to provide you with preferences for information filtering,  help you optimize your choices and interactions with advertisements, help determine your login status and account or data security.

2.1.2.     We do not use cookies for any purpose other than those described in this Policy. You can manage or delete Cookies based on your preference. You can clear all Cookies that stored on your computer, and most web browsers automatically accept cookies, but you can usually modify your browser settings to reject cookies if you wish. Alternatively, you can clear all cookies stored within the software. However, if you do so, you may be required to change your user settings each time you visit the CAftrade and related services, and any information you have previously recorded will be deleted and may have an impact on the security of the services you use.

2.2.  To recommend, display, or promote content or accounts that may be of interest to you

2.2.1.     We may use cookies and similar technologies to understand your preferences and usage habits, to conduct data analysis and to improve our products and services, to recommend information or function of interest to users and optimize your choice of advertising.

2.2.2.     In the “Discover” page of the CAftrade, we may use Cookies to record viewing activity, recommend information to you and troubleshoot crashes, latency-related anomalies and to explore better ways to serve you

2.3.  Clearing cookies

Most browsers provide users with the fuction to clear their browser cache data, and you can do so in the browser settings. If you do so, you may not be able to use the services or corresponding functions provided by the company based on cookies due to these modifications.


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

3.1.  Sharing principles

(a) With your prior express consent or authorization;

(b) Provided in accordance with applicable laws and regulations, the requirements of legal proceedings, and mandatory administrative or judicial requirements as may be necessary;

(c) To the extent permitted by laws and regulations, it is necessary to protect the interests, property or safety of CAftrade, CAftrade affiliates or partners, you or other CAftrade users or the public from damage;

(d) Only if your personal information is shared can the core function of our products and/or services be realized and the services you require be provided;

(e) At your request to handle disputes or controversies between you and others for you;

(f) Provided in compliance with the relevant agreements signed with you (including the electronic agreements signed online and the corresponding platform rules) or other legal documents;

(g) Used for academic research purposes;

(h) Used in the public interest in accordance with laws and regulations.

3.2.  Shared information for the implementation of functions or services

3.2.1.     When you use the functions of CAftrade provided by our associated party or third parties, or when software service providers, smart device providers, system service providers and us jointly provide services to you, we may share necessary information to fulfil our business with these associated party or third parties in order to recommend, display specific functions, services or advertisements that are more suitable for you.

3.2.2.     Login, binding to other products: with your consent, when you use your account to login to a third party's products or services or bind your account to other third party accounts, we may share your nickname, avatar, followers, other relationships and other information you authorize with the aforementioned products or services. When logging in with a third-party account, necessary information for logging in may need to be written to and read from the clipboard. This information is only used for the purposes associated with logging-in, and no private information about you will be collected.

3.2.3.     When you use the third party applet service accessed by "CAftrade", the applet may use the relevant system permissions authorized by you, or may require you to submit personal information according to the function of the applet. We will provide necessary information for the service to the third party applet for your service according to your authorization. You can refer to the third party service related agreement or privacy policy, you can also withdraw your authorization in the applet.

3.2.4.     Geolocation Services: when you use geolocation-related services, we may share GPS information with our location service provider so that we can return location results to you. When you use the weather-related searching services, we may share the GPS information with the weather service provider to provide you with more accurate weather services in your area. GPS information is sensitive personal information, and if you refuse to provide it, it will only affect the geolocation service function, but not the normal use of other functions.

3.2.5.     Payment function: the payment function is provided to you by the third-party payment institutions that we cooperate with. The third party payment institution may need to collect your name, bank card type, card number, expiration date and mobile number. The bank card number, expiration date and mobile number are personal sensitive information necessary for the payment function. Refusal to provide them will result in your inability to use the function, but will not affect the normal use of other functions.

3.2.6.     Purchased service function: When you use the "Purchased service" function, we may share your order information with the relevant service provider for your convenience after you have authorized us to do so.

3.2.7.     In order to adapt the message push function to the terminal model you are using, we may share the phone model, version and related device information with the terminal device manufacturer through SDK and other technologies.

3.3.  Realization of advertising-related shared information

3.3.1.     Advertising delivery and placement: we may share information with partners for promotion and advertising delivery, but we will not share information that can be used to identify you personal information (name, valid personal ID number), and will only provide these partners with indirect profile tags and de-identified or anonymized device, network and channel information that cannot identify you personally, so as to help them improve the effective reach of advertising without identifying your personal information. You may refuse to be reached by our advertising. You may refuse to allow us to deliver programmatic advertising to you without affecting your use of other CAftrade functions or services.

3.3.2.     Advertising statistics: we may share and analyze de-identified statistical information with service providers, suppliers and other partners of our business. This information is difficult to associate with your identity information and will help us analyze and measure the effectiveness of advertising and related services.

3.4.  Transfer or merger of information

3.4.1.     We will not transfer your personal information to any other third party unless we have your express consent.

3.4.2.     As our business continues to grow, we may engage in mergers, acquisitions, and asset transfers, and your personal information may be transferred as a result. In the event of such a change, we will require the successor party to re-obtain your authorized consent in accordance with laws and regulations and security standards no less stringent than those set forth in this Policy.

3.5.  Disclosure of information

3.5.1.     We will not publicly disclose your information except in accordance with national laws and regulations or with your consent. We will use security measures that meet industry standards to protect your personal information when we disclose it publicly.

3.5.2.     We will disclose account information when we announce penalties for account violations and fraud. If you violate laws or regulations or the relevant agreements and rules of the CAftrade, or for protecting the personal and property safety of CAftrade or the public, we may disclose your personal information in accordance with laws and regulations, the agreement, or with your consent.

3.5.3.     For public welfare projects such as "Person Search" and "Fugitive Tracking", we will publicly disclose information related to the incident after complying with the laws and regulations and expressly authorized. When the event is over, we will delete the disclosed personal sensitive information in time.

3.5.4.     When you authorize the game or applet or other functions or services, the avatars and nicknames of you and your friends will be displayed in the ranking and related functions.

3.5.5.     Your publicly released works and followed items will be displayed in your personal homepage.


4.      How we protect and store your personal information

4.1.  Our technology and measures to protect your personal information

4.1.1.     We attach great importance to the security of personal information and will endeavor to take all reasonable and feasible security measures (including technical and administrative measures) to protect your personal information from improper use or unauthorized access, public disclosure, use, modification, damage, loss or leakage.

4.1.2.     We will protect your personal information as far as possible using encryption technology, anonymization and related reasonable and practicable means that meet industrial standard, and use security protection mechanisms to prevent malicious attacks on your personal information.

4.1.3.     We will establish special security departments, security management systems, and data security processes to protect the security of your personal information. We adopt a strict data use and access system to ensure that only authorized personnel have access to your personal information, and conduct security audits of data and technology from time to time.

4.1.4.     We have adopted reasonable and effective measures as described above, and have complied with the standards required by the relevant legal provisions. However, please understand that due to technical limitations and the possibility of various malicious means, in the Internet industry, even with all efforts to strengthen security measures, it is not always possible to guarantee the 100% security of the information. And we will do our best to ensure the security of the personal information you provide to us.

4.1.5.     You acknowledge and understand that the systems and communication networks you use to access our services may experience problems due to factors outside of our control. Therefore, we strongly recommend that you take proactive measures to ensure the security of your personal information, including, but not limited to, using complex passwords, changing passwords regularly, and not disclosing your account password and related personal information to others.

4.1.6.     We will develop contingency plans and immediately activate them in the event of a user information security incident in an effort to prevent the expansion of the impact and consequences of such security incidents. Once a user information security event (leakage, loss) occurs, we will promptly inform you of: the basic situation and possible impact of the security event, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce the risk and the remedial measures for you, in accordance with the requirements of laws and regulations. We will promptly inform you of the incident in the form of push notifications, Emails, letters, SMS and related forms; and when it is difficult to inform you one by one, we will take reasonable and effective ways to issue announcements. At the same time, we will also report the disposition of user information security incidents in accordance with the requirements of relevant regulatory authorities.

4.1.7.     Once you leave the CAftrade and related services to browse or use other websites, services and content resources, we will have no ability or direct obligation to protect any personal information you submit on the software, websites, or services other than the CAftrade software and related services, whether or not your access to, browsing of, or use of such software or website is based on a link or lead from CAftrade.

4.2.  The storage of your personal information

4.2.1.     Your personal information will be stored in the People's Republic of China. If you use cross-border transaction services and need to transfer your personal information abroad to complete the transaction, we will obtain your authorization and consent separately and require the receiving party to process such personal information in accordance with our instructions, this Policy and any other relevant confidentiality and security measures.

4.2.2.     During your usage of our products and/or services, your personal information will be preserved within the time limit of achieving the purpose of this Policy as described, and it will simultaneously combine with the provisions of the law according to which forced retained demand period is required. For example, the Electronic Commerce Law of the People's Republic of China requires that the preservation time of the information of goods, services and transactions shall be no less than three (03) years from the date of transaction completion. After the retention period, we may delete or anonymize your personal information as required by applicable law.

4.2.3.     Please note that after you successfully cancel your CAftrade account, we will delete or anonymize your personal information. When you delete relevant information by yourself or with our help, due to the limitations of applicable legal and security technology, we may not be able to immediately remove the corresponding information from the backup system. We will securely store your personal information and limit any further processing of it until the backup can be deleted or anonymized.

4.2.4.     If we terminate our services or operations, we will notify you at least thirty (30) days in advance and delete or anonymize your personal information after we terminate our services or operations.


5.      How to manage your personal information

CAftrade attaches great importance to your concerns about personal information, and will do its best to protect your rights to access, correct, delete and withdraw consent to your personal information, so that you can fully protect your privacy and security. Your rights include:

5.1.  Access and correct your personal information

Except as provided by laws and regulations, you have the right to access and correct your personal information at any time, including:

5.1.1.     Your account information.

If you access the website of CAftrade (www.caftrade.com), you can check all your account information by clicking "My page" of homepage. You can also update other personal information except your real name authentication information through the above channel (your real name authentication information is the name and valid identity ID information used when you pass the real name authentication). If you need to change your real name authentication information, you can call customer service to apply for change.

If you access the mobile application of CAftrade (Android and IOS), you can check all your account information by clicking “Account” of homepage.

5.1.2.     Your browsing information: you can access or clear your search history, view and modify your interests, and manage other data.

5.1.3.     Your comment information: you can access your personal comments or make follow-up comments on the platform information.

5.1.4.     Your invoice information: you can access or update or clear your invoice information.

5.1.5.     Access or correction of other personal information: If you need access or correction of other personal information generated during the use of our products and/or services, please feel free to contact us. We will respond to your request in the manner and period specified in this Policy.

5.1.6.     The personal information that you can't view and change: in addition to the above information, we cannot provide services for you to view and change some other personal information. Such information mainly includes your equipment information collected for improving user experience and ensuring transaction security, and your personal information generated when using extended functions. The above information will be used within the scope of your authorization. You can not view or correct it, but you can contact us for deletion or anonymization.

5.2.  Delete your personal information

You may request us to delete your personal information under the following circumstances:

(a) If our handling of personal information violates laws and regulations;

(b) If we have collected or used your personal information without your consent;

(c) If our processing of personal information violates our agreement with you;

(d) If you no longer use our products or services, or you have canceled your CAftrade account;

(e) If we terminate the services and operations.

If we decide to respond to your deletion request, we will also notify the entities that received your personal information from us and request them to delete it in a timely manner, unless otherwise provided by laws and regulations or require these entities to obtain your separate authorization. If we respond to your delete request, we cannot guarantee that the information will be deleted from the backup system immediately, but we will delete the information when the backup system is updated.

5.3.  Change the scope of your authorization and consent or withdraw your authorization

You may change the scope of your authorization to continue to collect personal Information or withdraw your authorization by deleting information, turning off device functions or changing settings on the CAftrade website or software. You may also revoke all of our authorization to continue collecting your personal information by closing your account.

Please understand that the completion of each business function requires some basic personal information to complete its function. After you withdraw your consent or authorization, we cannot continue to provide you with the services corresponding to the withdrawal of consent or authorization, and will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the prior processing of personal information based on your authorization.

5.4.  Cancel account

You can directly apply for cancellation of your account in our products. For the relevant rules on account cancellation, please refer to the CAftrade Account Cancellation Agreement. After you cancel your account, we will stop providing you with products and/or services, and according to your request, unless otherwise provided by laws and regulations, we will delete your relevant personal information.

5.5.  Require a copy of your personal information

You have the right to require a copy of your personal information. If you need to require a copy of your personal information collected by us, please feel free to contact us. We will provide you with a copy of your personal information upon your request on the premise of complying with relevant laws and regulations and the availability of technology.

5.6.  If you do not want to accept the promotional information we send you, you can cancel it at any time by the following means:

(a) You can unsubscribe from promotional information through the account settings page on the website of our product;

(b) You can cancel the mobile phone promotional SMS service that we send to you according to the prompt of the promotional SMS content;

(c) You can also make related settings to cancel the promotional information through the settings page of our product’s mobile application;

(d) We will cooperate with third-party platforms or media (hereinafter referred to as "platforms") to recommend personalized products to you based on your personal information. This personal information includes information, such as the use of products and/or services on the website, access to the website of affiliated companies on the website and interests you have entered in your account settings page. The platform only provides us with a window to display goods, and the link of the window content is the personalized display information of goods on the CAftrade website, which is managed by CAftrade. Therefore, we will not provide any of your personal information to advertisers. You can choose to screen the advertisement you do not like through screen function in the recommendation window. If you are not willing to accept CAftrade's recommendation service on a platform, please contact the platform to close it. You acknowledge and understand that the platform is a self-operating entity and CAftrade does not manage it.

(e) In order to protect your privacy, we will not recommend you any promotion or product information related to religious belief, sexual orientation or other sensitive content in any way.

5.7.  To response your request

If you cannot access, correct or delete your personal information by the way above, or you need to access, correct or delete your other personal information when using our products and/or services or to obtain a copy of the personal information, or you think CAftrade has violated any laws and regulations or agreements with you about the collection or use of your personal information, you may contact us by email at service@caftrade.com or through other means specified in this Policy. For security purposes, we may require you to provide a written request and your identification document, and we will respond to your request within fifteen (15) days after receiving your feedback and verifying your identity. For your reasonable request, we do not charge in principle, but for repeated requests which is beyond the reasonable limit, we will charge a certain cost according to the situation. We may refuse requests that are unreasonable, that require excessive technical means (for example, the development of new systems or fundamental changes in existing practices) and pose a risk to the legal rights of others or that are highly impractical.

Under the following circumstances, we will not be able to respond to your request in accordance with laws and regulations:

(a) Those related to the performance of the obligations prescribed by laws and regulations by the personal information holder;

(b) Those related to national security and national defense security;

(c) Those related to public safety, public health or major public interest;

(d) Those relating to criminal investigation, prosecution and trial and enforcement of judgments;

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

(f) For the purpose of safeguarding the life, property and other important legal rights and interests of the subject of personal information or other individuals but difficult to obtain the consent of the subject;

(g) Responding to your request will seriously damage the legitimate rights and interests of you or other individuals or organizations;

(h) Those involving trade secrets.


6.      The protection of personal information for minors

6.1.  CAftrade attaches great importance to the protection of minors' personal information. If you are under the age of 18, you should obtain the consent of your guardian before using our products and/or services. CAftrade protects minors' personal information in accordance with relevant national laws and regulations.

6.2.  We do not collect personal information directly from minors on our own initiative. We will only use, share, transfer or disclose the personal information of minors collected with the consent of the guardian if it is permitted by law, with the consent of the guardian or necessary for the protection of minors.

6.3.  If it is proven that minors have registered and used our products and/or services without the consent of their guardians, we will negotiate with the guardians concerned and try to delete the relevant personal information as soon as possible.

6.4.  We further take the following measures to protect the personal information of children under the age of 14 that may be involved:

6.4.1.     For children's personal information collected, in addition to comply with our Policy regarding personal information provided, we will also adhere to the principles of proper necessity, informed consent, clear purpose, security and lawful use, and strictly follow Regulations on the Protection of Children's Personal Information Online and the requirements of other laws and regulations for storage, use, disclosure, and do not exceed the time limit necessary for the purpose of collection and use, and we will delete or anonymize the children's personal information after the expiration. We will designate special personnel and set up a special email service@caftrade.com to protect children's personal information. We will also develop a dedicated internal system for the protection of children's personal information.

6.4.2.     When you, as a guardian, choose to use CAftrade services for your children under your guardianship, we may need to collect the personal information of your children under your guardianship for the purpose of performing relevant services to you. If we need to collect children's personal information from you in specific services, we will obtain your authorization and consent in advance, and inform you of the purpose and use of collection. If you do not provide the above information, you will not be able to enjoy the relevant services provided by us. In addition, you may voluntarily provide us with children's personal information when you share product-related information by using the functions of listing, evaluation and Q&A,  and please be aware of this and cusehoose it carefully. As the guardian, you should correctly perform the guardianship duties and protect the safety of children's personal information. If children themselves need to register or use our products and/or services, you should guide and monitor them properly.

6.4.3.     The child or his/her guardian has the right to access and correct the child's personal information at any time, and may request us for correction and deletion. If you have any comments, suggestions, complaints or reports about children's personal information, please contact us. We are always here to help you.


7.      Notice and revision of this Policy

7.1.  In order to provide you with better service and with the development of CAftrades business, this Policy will be updated accordingly. However, we will not reduce your rights under this Policy without your express consent. We will send an updated version on the CAftrade website and the CAftrade mobile application and remind you of the update of the relevant content through the announcement on the website or in other appropriate ways before it takes effect. You are also invited to visit CAftrade to keep abreast of the latest Policy.

7.2.  For major changes, we will also provide more prominent notice (we will explain specific changes to the Policy by means including but not limited to email, SMS or special reminders on the browsing page).

Material changes referred to in this Policy will include, but are not limited to:

7.2.1.     Major changes have taken place in our service model. For example, the purpose of personal information processing, the type of personal information processing, the use of personal information, etc.

7.2.2.     We have undergone major changes in ownership structure, organizational structure, etc., such as changes of owner caused by the business adjustment, bankruptcy merger and acquisition;

7.2.3.     The main object of personal information sharing, transfer or public disclosure changes;

7.2.4.     Your rights to participate in the processing of personal information and the way in which they are exercised change significantly;

7.2.5.     Our responsible departments, contact methods and complaint channels for handling personal information security change;

7.2.6.     When the privacy information assessment report indicates that there is a high risk.

7.3.  We will also archive older versions of this Policy for your review.

7.4.  In order to receive notifications in a timely manner, you are advised to notify us when your contact information is updated. If you continue to use our services after this policys update takes effect, it means that you have fully read, understood and accepted the updated policy and are willing to be bound by the updated policy. We encourage you to review this policy every time you use our services.


8.      How to contact us

8.1.  If you have any complaints, reports, questions, comments or suggestions about this Policy or your personal information, please contact us through the following methods.

Person in charge of personal information protection

Email: service@caftrade.com

Contact number: 4009030175

Contact address: 5-11, Building 3, No. 37, Jingyang Road, Shapingba District, Chongqing, China

Developer: Qihong (Chongqing) Technologies Co., Ltd.

You can also contact us at any time through the online customer service system or dialing our customer service telephone.

8.2.  Normally, we will give you a reply within fifteen (15) days. If you are not satisfied with our response, especially if your legitimate rights and interests are harmed by our personal information processing, you can also complain or report to the relevant regulatory authority.


9.      Other

All the content of this Policy is available in Chinese, English and French. In the event of any discrepancy in understanding the relevant content of the Policy, the Chinese version of the Policy shall prevail.