Tocoding Technology Co., Ltd. (hereinafter referred to as “we”) attaches great importance to user privacy and personal information protection. When you use our products and/or services, we may collect and use your relevant information. We hope to use the “Privacy Policy” to explain to you how we collect, use, save, share and transfer this information when you use our products and/or services, as well as the access, update, deletion and protection we provide you with Way of information.

 

This privacy policy will help you understand the following:

  • How we collect and use your personal information
  • How do we store your personal information
  •  How do we share, transfer, and publicly disclose your personal information
  • How do we protect your personal information
  • Your right to manage personal information
  • Protection of personal information of minors
  • Scope of application of the privacy policy
  • Changes and revisions to the privacy policy
  • How to contact us
  • Effectiveness of Privacy Policy

 

We hope to use this privacy policy to explain to you how we collect, use, store, and share your personal information when using a ToSee account, as well as the methods we provide you to access, update, delete and protect this information. Before using your ToSee account, please read and understand this privacy policy carefully, and use our products or services after confirming your full understanding and consent. Once you start using the ToSee account, it means that you have fully understood and agreed to this policy, and agreed that we collect, use, store and share your relevant information in accordance with this privacy policy. If you have any questions, comments or suggestions about the content of this policy, you can contact us through the various contact methods provided in this privacy policy.

 

I. How we collect and use your personal information

We will collect and use your personal information for the following purposes described in this privacy policy:

(I)Circumstances under which you must authorize us to collect and use your personal information

  1. Location-based features

When you open the ToSee APP, you can choose whether to allow our product to collect your GPS location information through the pop-up window. If you agree to our collection of your GPS location information, this information will only be used to obtain the WiFi connected to your phone based on your location, the WiFi list of your phone, and use the background location to select WiFi to help the device connect to the network. ToSee will not use the above information for purposes other than the realization of the above functions. Refusal to provide location information will only make you unable to enjoy the device search based on location information when adding a device and choose to connect to the network, and will not affect your normal use of other functions of this product.

Extended functions based on the camera (camera)

You can use this extended function to complete the function of scanning and sharing the QR code when sharing the device.

  1. Extended function based on image upload: you can upload and scan the QR code image stored in the phone photo when sharing the device
  2. The extended function of album based on image downloading and saving: You can use this extended function to store the video screenshot in your mobile phone album.

(II) Personal information to be collected by third parties integrated in the APP:

Youmeng Statistics SDK: installed application version and distribution channels of mobile phone users, IP address and network status, APP crashes, APP use time, number of starts, pages visited, mobile device model, network type, user retention status. When the SDK is initialized, custom events and data statistics are collected for the purpose of analyzing user behavior data, using paths, and discovering functions to be optimized.

Share SDK: It integrates (email, WeChat, QQ) to collect your IP address, operating system, WeChat software version number, access to the network, type and status, network quality data, device accelerator, service failure information, and other logs information. When you choose to share the event video to WeChat, Email or QQ, it is used to ensure a smooth sharing path and follow-up to find out the factors affecting the unsuccessful sharing.

UC Woodpecker SDK: Collect app freezes and crashes, and use it for Umeng statistics of APP bugs

 

(III) How do we use cookies and similar technologies

Use of Cookies

(1) In order to realize the personalized needs of your online experience, so that you can get a more relaxed access experience. We will send one or more small data files called Cookies on your computer or mobile device. The Cookies assigned to you are unique and can only be read by the web server in the domain that issued the Cookies to you. We send you Cookies to store your camera device data, and then provide you with help, optimize the choice and interaction of advertisements, help judge your device status and data security.

(2). We will not use cookies for any purpose other than those stated in this privacy policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer. Most web browsers will automatically accept cookies, but you can usually modify your browser settings to reject cookies according to your needs; in addition, you can also clear all cookies saved in the software . But if you do this, you may need to personally change the user settings every time you visit ToSee, and the corresponding information you have recorded before will also be deleted, and it may have a certain impact on the security of the services you use.

Use of network Beacon and similar technologies

In addition to Cookies, we also use Web Beacon and other similar technologies on the website. Our web pages often contain electronic images (called “single pixel” GIF files or “web beacons”). The ways we use network Beacon are:

(1) Calculate the number of user visits and stay time by using the network Beacon on ToSee;

(2) Provide you with personalized services through the cookies information obtained.

 

(4). Improve our products and services

User experience improvement. When you use the ToSee APP, we may collect the International Mobile Equipment Identity (IMEI) and network device address (MAC) encrypted by the MD5 algorithm, the advertising identifier IDFA, device model, system version number, operating system version number, System number, system ID number, screen resolution, Internet access type, version number of this product, time and frequency of using a button, option values of some key configurations, software crash logs, etc., used to count the users of our products Quantity, analyze the use of the product, investigate the cause of the crash, and reduce the crash, so as to continuously improve our products. This information does not involve private information such as your personal identity.

 

(5). Security

In order to improve the security of your use of the services provided by us and our affiliates and partners, protect the personal and property safety of you or other users or the public from infringement, and better prevent phishing websites, fraud, network vulnerabilities, computer viruses, and network attacks , Network intrusion and other security risks, to more accurately identify violations of laws and regulations or ToSee related agreement rules. We may use or integrate your account information, device information, software usage information, and information that our affiliates and partners have obtained your authorization or shared in accordance with the law for identity verification, detection and prevention of security incidents, and to take necessary actions in accordance with the law. Recording, auditing, analysis, and disposal measures.

 

(6). Other uses

Under the premise of complying with laws and regulations, we may anonymize, aggregate, desensitize and encrypt your personal information to form statistical information or user portrait (but the portrait cannot identify any individual user), and display and push for you Related services, products or functions. If we use the information for other purposes not specified in this policy, or use the information collected for a specific purpose for other purposes, we will seek your consent in advance.

 

(7) Exceptions for obtaining authorization and consent

According to relevant laws and regulations, the collection of your personal information in the following situations does not require your authorization and consent:

  • Related to national security and national defense security;
  • Related to public safety, public health, and major public interests;
  • Related to criminal investigation, prosecution, trial and execution of judgments;
  • In order to protect the life, property and other major legal rights of personal information subjects or other individuals, but it is difficult to obtain your own consent in time;
  • The personal information collected is disclosed to the public by yourself;
  • Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
  • Necessary for signing a contract according to your requirements;
  • Necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and disposing of product or service failures;
  • Necessary for legal news reporting;
  • When academic research institutions conduct statistical or academic research based on the public interest, and when they provide academic research or description results externally, they de-identify the personal information contained in the results;
  • Other circumstances stipulated by laws and regulations.

 

II. How do we store your personal information

The personal information we collect and generate within the territory of the People’s Republic of China will be stored in the territory of the People’s Republic of China.

If in order to process cross-border business, it is necessary to transmit relevant personal information collected in China to overseas institutions, we will implement it in accordance with laws, administrative regulations and relevant regulatory authorities. We will ensure that your personal information is adequately protected, such as anonymization, encrypted storage, etc.

We only store your personal information for the period necessary for the purpose of this policy and within the time limit required by laws and regulations.

If we stop operating ToSee’s products or services, we will promptly stop continuing to collect your personal information, will notify you of the stop of operations in the form of one-by-one delivery or announcement, and delete or anonymize the personal information we store deal with.

 

III. How do we share, transfer, and publicly disclose your personal information

(I)Sharing

We will not share your personal information with any company, organization or individual, except in the following circumstances:

  • With your explicit consent, we will share your personal information with other parties.
  • We may share your personal information with external parties in accordance with laws and regulations, the need for litigation dispute resolution, or the requirements of administrative and judicial organs in accordance with the law.
  • To the extent permitted by laws and regulations, it is necessary to share your personal information in order to protect the interests, property or safety of ToSee, ToSee’s affiliates or partners, you or other ToSee users, or the public from damage.
  • In cases where our affiliates provide services to you or to us, we may share your personal information with our affiliates. However, we only share necessary personal information, and the processing of your information by related parties is governed by this privacy policy. If the affiliated company wants to change the purpose of processing your personal information, it will again seek your authorization and consent.
  • Unless we have your explicit authorization and consent, we will not share your personal information with third-party advertisers, application developers, open platforms or other partners. We may provide these partners with aggregated information, anonymized information, or other information that does not identify you personally. For example, we may tell application developers how many people have installed the application they developed.
  • Only for the purposes stated in this privacy policy, we may share your personal information with our suppliers, service providers, consultants or agents to provide better customer service and user experience. These vendors, service providers, consultants, and agents may provide us with technical infrastructure services, analyze how our services are used, measure the effectiveness of advertisements and services, provide customer service and payment services, conduct academic research and surveys, or Provide legal, financial and technical advisory services. For example, we may occasionally invite registered users to participate in sweepstakes. If you are lucky enough to win the prize, we need to provide your personal information to the logistics service provider in order to send you our prizes.

For companies, organizations and individuals with whom we share personal information, we will sign strict data protection agreements with them, requiring them to process personal information in accordance with our instructions, this privacy policy and any other relevant confidentiality and security measures.

(II). Transfer

We will not transfer your personal information to any other companies, organizations or individuals, except in the following circumstances:

  • With the development of ToSee’s business, we and our affiliated companies may conduct mergers, acquisitions, asset transfers or other similar transactions. If the relevant transaction involves the transfer of your personal information, we will require the new company, organization and individual that holds your personal information to continue to be bound by this policy, otherwise we will require the company, organization and individual to re-obtain your authorization and consent.
  • Transfer with your explicit consent, that is, after obtaining your explicit consent, we will transfer your personal information that we have obtained to other parties.

 

(III). Disclosure

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

  • Your explicit consent has been obtained.
  • We may publicly disclose your personal information when required by law, legal procedures, courts or relevant government departments.
  • Other circumstances stipulated by laws and regulations.

 

IV. How do we protect your personal information

We have adopted industry-standard security protection measures to protect the personal information you provide to prevent unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonable and feasible measures to protect your personal information.

 

  1. We will encrypt the transmission and storage of identifiable personally identifiable information to ensure the confidentiality of data. For your mobile device identifier International Mobile Equipment Identity (IMEI) and network device address (MAC), we will use the MD5 algorithm for anonymization and encryption on your device, and only collect and upload the anonymized and encrypted information Identifier.
  2. If our application uses WebView technology, we will verify URLs for all file protocols used in WebView and restrict access to sensitive data and SDCard data in this application to avoid any private use of ToSee products without special permissions. Files and sensitive information are maliciously stolen, causing your personal information to be leaked.
  3. We deploy an access control mechanism on the server, adopt the principle of minimum sufficient authorization for staff who may have access to your personal information, and regularly check the list of visitors and access records.
  4. Our server systems that store users’ personal information are all security-hardened operating systems. We will conduct account audit and monitoring of server operations. If an externally announced server operating system with security issues is found, ToSee will update the server security as soon as possible to ensure the security of all ToSee server systems and applications.
  5. We regularly organize trainings on personal information protection related laws and regulations for staff to strengthen the staff’s awareness of user privacy protection.
  6. In the unfortunate event that our physical, technical or management protection measures are damaged, we will promptly activate emergency plans to prevent the expansion of security incidents, report to the national competent authority in accordance with the requirements of laws and regulations, and promptly adopt reasonable pushes, announcements, etc. , Effective ways to inform you of the basic situation, possible impact, measures that have been taken or measures to be taken, etc. of the security incident.

V. Your right to manage personal information

During your use of ToSee APP, you can access and manage your personal information in the following ways:

(I) Delete your personal information

You have the right to request ToSee to delete your personal information when the following situations occur:

  • We have collected your personal information without asking for your explicit consent.
  • Our processing of your personal information violates the requirements of laws and regulations.
  • We have violated our agreement with you to use and process your personal information.
  • You uninstall or no longer use our products (or services).
  • We stop providing services to you.

You can contact us to request the deletion of your personal information through the methods provided in section 9 of this privacy policy, and we will reply within 15 working days. After we delete your personal information from the server, we may not delete the corresponding data from the backup system immediately, but we will delete this information when the backup is updated.

(II). Withdraw your consent or authorization

You can withdraw your consent to the collection and use of your personal information by turning off the function of the device. For this product, you can turn off the permission for us to collect your GPS location information, turn off the camera permission, and turn off the album permission through the settings of your phone.

Please understand that each business function requires some basic personal information to be completed (see the first section of this privacy policy). After you withdraw your consent or authorization, we cannot continue to provide you with the services corresponding to the withdrawal of your consent or authorization. Corresponding personal information will no longer be processed. However, your decision to withdraw your consent or authorization will not affect the previous processing of personal information based on your authorization.

 

VI. Protection of personal information of minors

When minors use ToSee products (or services), they need the consent and authorization of their guardians. We recommend that minors’ parents or guardians read this privacy policy for them, and recommend that minors seek the consent and guidance of their parents or guardians before submitting personal information. If you are the guardian of a minor, when you have any questions about the personal information of the minor under your supervision, you can contact us through the contact information in Section 9 of this Privacy Policy.

 

VII.the scope of application of the privacy policy

This privacy policy only applies to all ToSee products and services. In particular, it should be noted that this privacy policy does not apply to the following situations:

Embed ToSee products (or services) into third-party products (or services), and information collected by third-party products (or services).

VIII. Changes and revisions to the privacy policy

Our privacy policy may change. Without your explicit consent, we will not restrict your rights in accordance with this privacy policy.

For major changes to this privacy policy, we will also provide noticeable notifications (for example, when the software is revised or upgraded, or when you log in again, we will promptly notify you in the form of a pop-up window).

 

The major changes referred to in this policy include but are not limited to:

  1. Our service model has undergone major changes. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;
  2. Significant changes have taken place in our control and other aspects. Such as owner changes caused by mergers and acquisitions, etc.;
  3. Changes in the main objects of personal information sharing, transfer or public disclosure;
  4. Your right to participate in the processing of personal information and how to exercise it has undergone major changes;
  5. When our responsible department, contact information and complaint channels for handling personal information security change;
  6. When the personal information security impact assessment report shows that there is a high risk.

IX. How to contact us

If you have any questions, comments, suggestions or complaints about our privacy policy and the handling of your personal information, please contact us at www.Tocoding.com.

Under normal circumstances, we will respond to your request within 15 working days.

 

X. Effectiveness of Privacy Policy

This privacy policy is officially effective today.