WorldTalk Privacy Policy (Updated on August 30, 2018)

Shanghai Lingfen Technology Co., Ltd. ( “We”) is (are) well aware of the importance of personal information to you, and we will do our best to ensure the security and reliability of your personal information. We are committed to maintaining your trust in us and protecting your personal information through adherence to the following principles: principle of responsibility in accord with authority, principle of definite purpose, principle of selective consent, principle of minimum use, principle of guaranteed security, principle of subject participation, principle of openness and transparency. We also undertake to take security protection measures based on proven security solutions in the industry to protect your personal information. For this end, we establish the WorldTalk Privacy Policy (the “Policy / Privacy Policy”) and remind you that:

The Policy applies to WorldTalk products or services. If the products or services of our affiliates use the products or services provided by WorldTalk (e.g., log in simply using WorldTalk account) but no privacy policy is separately set up, the Policy also applies to such products or services

It is specifically noted that the Policy does not apply to any service provided by any other third party for you, nor applies to any product or service in WorldTalk for which a separate privacy policy has been established.

It is specifically noted that the Policy does not apply to any service provided by any other third party for you, nor applies to any product or service in WorldTalk for which a separate privacy policy has been established.

Before you use each WorldTalk product or service, be sure to carefully read and thoroughly understand the Policy and make sure you have fully understood and consented to the Policy before use of the relevant products or services. Once you start to use any of WorldTalk products or services, this means you have fully understood and consented to the Policy. For any doubt, opinion or suggestion on the content of the Policy, you may contact us through various contact methods provided by WorldTalk

The Privacy Policy will help you understand the following items:

  1. 1、How we collect and use your personal information;
  2. 2、How we use Cookie and similar techniques;
  3. 3、How we share, transfer, publicly disclose your personal information;
  4. 4、How we protect your personal information;
  5. 5、How you manage your personal information;
  6. 6、How we treat minors’ personal information;
  7. 7、How your personal information is transmitted globally;
  8. 8、How the Privacy Policy is updated; and
  9. 9、How to contact us.

(I) Help you become our user

In order to complete the creation of an account so that we can provide services for you, you need to provide the following information: your nickname, head portrait, sex, birth date, mobile phone number/WeChat ID/QQ number, and create user name and password.

During registration, if you provide the following additional information to supplement your personal data, this will help us provide you with better service and experience: your real name, real identity information, hometown, relationship status, constellation, occupation, school, your own real head portrait. Nevertheless, if you opt not to provide such information, this will not affect your use of basic features of WorldTalk products or services.

For the foregoing information provided by you, you shall grant us a continued authorization to use such information during your use of the Service. When you actively deregister your account number, we will make such information anonymous or delete your personal information as required by applicable laws and regulations.

(II) Display and push goods or services to you

To improve our products or services and provide you with individualized information search and transaction service, we will, based on your browsing and search record, device information, location information, transaction information, extract your browsing, search preference, behavioral habits, location information and other features, and conduct indirect user profiling and display and push information based on feature tags.

If you do not want to receive commercial advertisements we send to you, you may cancel them from time to time through the subscription cancellation function of the corresponding product.

(III) Provide goods or services for you

Information provided by you for us

Relevant personal information provided by you for us while you are registering an account or using our services, e.g., telephone number, email, bankcard number or Alipay account number;

Sharing information provided by you for other parties through our services, and information stored by you while using our services. Before provision of the foregoing personal information of such other parties to WorldTalk, you shall make sure that you have obtained their authorization and consent.

Information collected by us during your use of services

In order to provide you with page display and search results more suitable for your requirements, learn about product suitability and identify any abnormal state of the account, we may collect information on the services you are using and the way you are using them, and link up such information, and such information may include the following:

Device information: We may, in accordance with specific authority granted by you during software installation and use, receive and record information relating to the device used by you (e.g., device model number, operating system version, device settings, unique device identifier and other hardware & software feature information), and information relating to device location (e.g., Idiv address, GdivS location and sensor information that can provide relevant information, such as Wi-Fi access point, blue tooth and base station. As the service provided by us is mobile social service provided on the basis of geographical location, your confirmation of the successful registered “WorldTalk” account number is construed as you having authorized us to extract, publicize and use your geographical location information).

Log information: When you use the products or services provided by our website or client app, we may automatically collect the particulars of your use of our services and save them as relevant network log. The foregoing particulars include your search and query content, Idiv address, browser type, telecom operator, language used, access date and time and the record of web pages accessed by you.

Please note that separate device information and log information is not enough to identify the identity of any particular natural person. If we use such non-personal information in combination with other information for the purpose of identifying the identity of any particular natural person, or use such information in combination with personal information, such non-personal information will be deemed as personal information during such combined use, and we will conduct anonymization and de-identification on such personal information, unless your authorization is obtained or otherwise required by laws and regulations.

When you contact us, we may save your communication/call records and contents or other information including contact information provided by you so that we may contact you or help you solve problems, or record the solutions and results of relevant problems.

Your personal information collected by us indirectly

You may use the products or services provided by our affiliates through your WorldTalk account number at link entries provided by us. In order to facilitate our joint provision of one-stop service for your based on associated account number and facilitate your centralized management, we display your information or recommend information of your interest in a concentrated manner at WorldTalk, including video, tourism, education, dating, live broadcast, gaming information

When you use the foregoing services through our products or services, you authorizes us, based on the actual business and cooperation needs, to receive from our affiliates, summarize and analyze your personal information or transaction information whose sources are lawful confirmed by us or that you consent and authorize them to provide for us.

If you refuse to provide the foregoing information or refuse to offer your authorization, you may be unable to use our affiliates’ corresponding products or services, or be unable to display relevant information, but this does not affect your use of WorldTalk’s core services like browsing, chat and dynamic update.

(IV) Provide security assurance for you

It is noted that: in order to ensure the authenticity of user identity and the provision of better security assurance for you, you may provide us with identity information like ID card, military officer certificate, passport, driver’s license, social security card and residence permit, biometric information like facial features, and personal sensitive information like Zhima Credit for the purpose of real name authentication.

In order to increase the security of your use of the services provided by us, our affiliates and partners, protect personal and property safety of you or other users or general public, better the prevention on security risks like phishing websites, fraud, network loopholes, computer viruses, network attack and network intrusion, and more accurately identify the violations of laws & regulations or WorldTalk’s relevant protocol rules, we may use or integrate your user information, transaction information, device information and relevant network log as well as information shared by our affiliates and partners subject to your authorization or in accordance with laws, to comprehensively judge the risks of your account and transactions, conduct authentication, detection and prevention of security events, and take necessary recording, audit, analysis and handling measures according to law.

(V) Other purposes

If we use information for any purpose other than those specified in the Policy or use any information collected for a particular purpose for any other purpose, we will obtain your prior consent.

(VI) Exceptions to authorization and consent

In accordance with the stipulations of relevant laws & regulations, collection of your personal information under any of the following circumstances is not subject to your authorization and consent:

  1. 1)Related to national security and national defense security;
  2. 2)Related to public security , public health or significant public interest;
  3. 3)Related to criminal investigation, prosecution, court trial and execution of judgment;
  4. 4)Intended to safeguard the life, property and other significant lawful rights and interests of the subject of personal information or other individuals while it is quiet difficult to obtain your personal consent;
  5. 5)Personal information collected is disclosed by yourself to the general public;
  6. 6)Personal information is collected from information lawfully disclosed in public, such as lawful channels like news coverage and government information disclosure;
  7. 7)Necessary for execution of the contract at your request;
  8. 8)Necessary for maintaining safe and stable operation of the products or services provided, e.g., identification and handling of defects in products or services;
  9. 9)Necessary for lawful news coverage;
  10. 10)Necessary for statistical or academic research by institutions for academic research based on public interest, and during their provision of academic research or description of results, personal information included in results is subjected to de-identification;
  11. 11)Other circumstances required in laws & regulations.

If we stop the operation of WorldTalk products or services, we will timely stop the collection of you personal information, and will inform you of the notice of stopped operation through personal delivery or announcement, and delete or make anonymous personal information in our possession.

II. How we use Cookie and similar techniques

(I) Cookie

In order to ensure the website’s normal operation, provide you with more comfortable user experience and recommend the contents in which you may feel interested, we will store small data files with storage name of Cookie in your computer or mobile device. Cookie generally includes identifier, site name and some numbers and characters. With the help of Cookie, the website can store your preference and other data.

(II) Web beacons and pixel tags

In addition to Cookie, we may also use other similar techniques like web beacon and pixel tag on our website. For instance, an email sent by us to you may contain an address link that links to the contents of our website. If you click on that link, we will track such click to help us learn about your product or service preference so that we can proactively improve customer service experience. Web beacon is generally a transparent image implanted in a website or email. Thanks to pixel tags in an email, we can learn if the email is opened. If you do not want to be tracked in this way, you may exit from our mail list from time to time.

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

(I) Sharing

We will not share your personal information with any company, organization and individual other than WorldTalk service provider, except under the following circumstances:

Sharing after explicit consent: We may share your personal information with other parties after your explicit consent.

Sharing in legal situations: We may share your personal information with other parties in accordance with the stipulations of laws & regulations, the requirement of litigation and dispute resolution, or the requests made by administrative or judicial authorities according to law.

Sharing with affiliates: In order to facilitate our joint provision of services for you based on associated account number, recommend information in which you may feel interested, or protect the personal and property safety of WorldTalk’s affiliates or other users or general public, your personal information may be shared with our affiliates. We will only share necessary personal information (for instance, to enable you to use our affiliates’ products or services with your WorldTalk account, we may share your necessary account information with our affiliates). If we share your personal sensitive information or our affiliates change the use and handling purpose of personal information, we will solicit your authorization and consent again.

Sharing with authorized partners: For the purpose of fulfilling the purposes stated in the Privacy Policy only, some of our services will be jointly provided by us and our authorized partners. We may share some of your personal information with our partners so as to provide better customer service and user experience, e.g., arranging partners to provide services. We will share your personal information for lawful, rightful, necessary, specific and explicit purposes only, and will share personal information necessary for provision of services only. Our partners shall have no right to use shared personal information for any other purpose not related to products or services.

At present, our authorized partners include the following types:

Authorized partners engaged in advertising and analytical services. Unless we obtain your permission, we will not share your personal identity information (that means information that helps identify your identity, e.g., name or email box. Such information may enable relevant entities to contact you or identify your identity) with partners providing advertising or analytical services. We may provide such partners with information relating to the coverage and effectiveness of their advertisements instead of your personal identity information, or we will summarize such information so that it cannot identify you. Only when advertisers agree to comply with our advertisement release rules, we may tell them how their advertisements are received, or how many people have viewed their ads or have installed certain applications after viewing the ads, or provide such partners with statistical information that cannot identify personal identity (e.g., “male, aged 25-29, living in Beijing”), to help them learn about their audience or customers.

Suppliers, service providers and other partners. we will send information to suppliers, service providers and other partners supporting our business, and such support includes providing technical infrastructure services, analyzing the use patterns of our services, measuring the efficiency of advertisements and services, providing customer service, convenience in payment or conducting academic research and investigation.。

For companies, organizations and individuals with whom we share personal information, we will sign a strict data protection agreement with them and cause them to treat personal information in accordance with our instructions, the Policy and any other relevant secrecy and security measures.

(II) Transfer

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

Transfer after explicit consent: After obtaining your explicit consent, we may transfer your personal information to other parties;

In case of merger, acquisition or bankruptcy liquidation, or other circumstances involving merger, acquisition or bankruptcy liquidation, if transfer of personal information is required, we will request the new company, organization in possession of you personal information to be continually bound by the Policy; otherwise, we will request such company, organization and individual to solicit your authorization and consent again.

(III) Public disclosure

We may disclose your personal information in public under the following circumstances only:

After your explicit consent or based on your proactive selection, we may publicly disclose your personal information;

If we are convinced that you have violated laws & regulations or materially violated WorldTalk’s relevant protocol rules, or when it is necessary to protect personal and property safety of the users of WorldTalk and its affiliates or general public, we may, in accordance with laws & regulations or WorldTalk’s relevant protocol rules and after obtaining your consent, disclose your personal information, including relevant violation and the measures already taken by WorldTalk against you.

(IV) Exceptions to prior authorization and consent for sharing, transfer, public disclosure of personal information

Under the following circumstances, sharing, transfer or public disclosure of your personal information is not subject to your prior authorization and consent:

(1)Related to national security or national defense security;

(2)Related to public security, public health or significant public interest;

(3)Related to criminal investigation, prosecution, court trial and execution of judgment;

(4)For the purpose of safeguarding life, property and other significant lawful rights and interests of you or other individuals while it is quiet difficult to obtain your own consent;

(5)Personal information disclosed to general public by you on your own;

(6)Personal information is collected from information lawfully disclosed in public, such as lawful channels like news coverage and government information disclosure.

In accordance with legal stipulations, sharing and transfer of personal information that undergoes such de-identification that data receivers cannot recover and re-identify the subjects of personal information does not belong to sharing, transfer and public disclosure of personal information, and the storage and processing of such data does not require prior notice to you or your consent.

IV. How we protect your personal information security

(I) We have taken reasonable, practicable security protection measures in compliance with the industry’s common solutions to ensure the security of personal information provided by you and protect personal information from unauthorized access, public disclosure, use, modification, damage or loss. For instance, the exchange of data (e.g., credit card information ) between your browser and the server is subjected to encrypted protection under the SSL (Secure Socket Layer) protocol; we will use encryption technique to enhance the security of personal information; we will use trusted protection mechanisms to protect personal information from malicious attack; we will put in place the access control mechanism to make sure that only authorized personnel are given access to personal information; and we will organize training sessions on security and privacy protection to sharpen our employees’ awareness of the importance of protecting personal information.

(II) We have an industry-leading data security management system focused on data and oriented towards data lifecycle to enhance the security of the system in various dimensions as organizational construction, institutional design, personnel management and product technology.

(III) We will take reasonable, practicable measures to try and avoid collecting irrelevant personal information. We will retain your personal information within the period necessary for fulfilling the purposes stated in the Policy, unless an extension of such period is required or otherwise permitted by laws.

(IV) Internet is not an absolutely secure environment, so we strongly suggest that you should not use any communication method other than those recommended by WorldTalk to send your personal information. You may establish relationships and do the sharing with others through our service. When you create communication, transaction or sharing through our service, you may freely select the objects of communication, transaction or sharing as third parties that can view your transaction content, contact information, communication information or sharing content and other relevant information.

If you are aware of any leakage of your personal information especially your account or password, you are expected to contact WorldTalk’s customer service immediately so that we could take corresponding measures upon your application.

It is noted that the information that you voluntarily share or even publicly share during your use of our service may involve personal information or even personal sensitive information of you or others, e.g., pictures containing personal information that you opt to upload during your dynamic update or in public occasions like group chat or circles. You are required to consider more prudently whether or not to share or even publicly share the relevant information while using our services.

Please use a complicated password to help us guarantee the security of your account. We will make our best efforts to guarantee the security of any information that you may send to us.

Meanwhile, we will also report on the handling of personal information security events in accordance with the requirement of the regulatory authority.

V. How you manage your personal information

You may access and manage your personal information in the following manners:

(I) Access your personal information

You are entitled to access your personal information unless otherwise required by laws & regulations. You may access your personal information on your own in the following manners

Account information -- If you wish to access or edit personal identity information, mobile phone binding, payment information in your account, change your password, add security information or close your account, you may perform such operations on “My” page after account login.

Personal data -- If you wish to access or edit the nickname, head portrait, hometown, relationship status, birth date, constellation, occupation, school, hobby, location, footprint or others in your personal data, you may log in your account and perform such operations through “My”-“View or Edit Personal Data”

Dynamic information -- You may log in your account and access or delete the historical record of your dynamic releases through “My Circle”.

If you fail to access such personal information through the foregoing approaches, you may contact us through WorldTalk’s customer service. We will respond to your access request within 30 days.

For any other personal information that may be generated during your use of our products or services, we will provide you with such information in accordance with relevant arrangements in “(VII) Respond to your foregoing requests” of this Article.

(II) Correct or supplement your personal information

When you are aware of any error in our handling of your personal information, you shall have the right to request us to make correction or supplementation. You may put forward your request for correction or supplementation through the method stated in“(I) Access your personal information” of this Article.

(III) Delete your personal information

You may delete some of your personal information through the method stated in“(I) Access your personal information” of this Article.

Under the following circumstances, you may request us to delete your personal information:

If our treatment of personal information violates laws & regulations;

If we collect, use your personal information without your explicit consent;

If our treatment of personal information materially breaches the relevant agreement reached with you;

If you no longer use our products or services, or you proactively cancel your account number;

If we no longer provide you with products or services.

If we decide to respond to your deletion request, we will also try our best to notify all entities that have obtained your personal information from us and request them to delete such information timely, unless otherwise required by laws and regulations or such entities obtain your separate authorization.

After you delete information from our service, we might not delete corresponding information from our backup system promptly, but we will delete such information during backup update.

(IV) Change the scope of your authorization and consent

Each business function cannot be completed without some basic personal information (see Article I of the Privacy Policy). Additionally, for collection and use of additional personal information, you may contact WorldTalk’s customer service to grant or withdraw your authorization and consent.

After you withdraw your consent, we will no longer handle corresponding personal information. However, your decision to withdraw your consent does not affect the handling of personal information previously conducted on the basis of your authorization.

(V) Cancellation of account by subject of personal information

You may submit your account cancellation application on the “Cancel Account” page on your own.

After you cancel your account on your own, we will stop the provisions of products or services for you and delete or make anonymous your personal information in accordance with the requirements of applicable laws.

(VI) Restrict information system’s automatic decision-making

In some business functions, we may make decisions only based on non-artificial automatic decision-making mechanisms including information systems and algorithms. If such decisions materially affect your lawful rights and interests, you are entitled to request us to give explanations, and we will provide appeal methods without prejudice to WorldTalk’s business secrets or rights and interests of other users, or social and public interests.

(VII) Respond to your foregoing requests

In order to guarantee security, you may have to provide a written request or otherwise prove your identity. We may request you to demonstrate your own identity before handling your request.

We will respond within 30 days. If you are not satisfied with our response, you may complain through WorldTalk’s customer service.

For your reasonable request, we will not charge any fee on principle. However, for repeated requests beyond the limit of reasonableness, we will charge you certain costs depending on actual conditions. For requests that are repeated unreasonably, require too many technical measures (e.g., a need for development of a new system or radical transformation of existing practices) or jeopardize lawful rights and interests of others or are very unpractical, we will likely refuse such requests.

Under the following circumstances, in accordance with the requirements of laws & regulations, we will not respond to your request:

Related to national security and national defense security;

Related to public security, public health or significant public interest;

Related to criminal investigation, prosecution, court trial and execution of judgment;

There are sufficient evidences to prove that the subject of personal information is guilty of subjective malice or abuse of its right;

Response to your request will result in serious damage to lawful rights and interests of you or other individuals or organizations;

Involving business secrets.

VI. How we treat minors’ personal information

Minors shall not create their own user account without their parents’ or guardians’ consent. If you are a minor, you are advised to request your parents or guardians to read the Privacy Policy carefully, and use our service or provide us with information with your parents’ or guardians’ consent.

For collection of minors’ personal information due to minors’ use of our products or services with their parents’ or guardians’ consent, we may use, share, transfer or disclose such information only when permitted by laws & regulations, explicitly consented by relevant parents or guardians, or as required for protection of minors.

VII. How your personal information is transmitted globally

Personal information collected and generated during our operations within the People’s Republic of China will be stored in China except under the following circumstances:

Otherwise specifically required by laws & regulations;

Your explicit authorization is obtained;

You perform personal active acts via Internet, such as cross-border making friends/learning/tourism/dating/dynamic update.

For the above circumstances, we will provide sufficient protection for your personal information under the Privacy Policy

VIII. How the Privacy Policy is updated

Our Privacy Policy may be subject to change.

Without your explicit consent, we will not restrict any right that you may enjoy under the Privacy Policy. For any significant change, we will provide a conspicuous notice (including our notice of change in the form of a WorldTalk announcement or even a pop-up prompt for you).

For the purpose of the Policy, significant changes include but not limited to:

Significant change in our service model, e.g., purpose of treating personal information, types of personal information treated and use pattern of personal information;

Significant change in our control and other aspects, such as change of owners resulting from merger, acquisition and restructuring;

Change in main objects of sharing, transfer or public disclosure of personal information;

Significant change in your right to participate in treatment of personal information and the method of exercise of such right;

Change in our department responsible for ensuring personal information security, contact information and complaint channel;

When the impact assessment report on personal information security indicates a high risk.

We will also retain the old version of the Privacy Policy for your reference

IX. How to contact us

You may contact us in the following manners and we will respond to your request within 30 days

For any doubt, opinion or suggestion on the content of the Policy, you may contact us through WorldTalk’s customer service and online customer service in WorldTalk mobile APP;

Upon awareness of possible leakage of personal information, you may contact WorldTalk’s customer service for complaint or tip-off;

We have also set up a department specialized in personal information protection and you may contact this department.

If you are not satisfied with our response, especially you believe our handling of personal information harms your lawful rights and interests, you may bring a lawsuit before a court of law having jurisdiction in the domicile of the defendant.

Shanghai Lingfen Technology Co., Ltd.