Effective from 1st day, December of 2022 year
The following Policy applies to all applications, interactive features and services developed and operated by Henan Broadcasting System. (hereinafter the “APP Operator” or the “Operator”) for Elephant and all other associated applications, interactive features, services and communications (hereinafter collectively known as the “APP” or the “Elephant” as the context requires)provided for Elephant.
PLEASE READ THIS PRIVACY POLICY CAREFULLY AND MAKE SURE YOU FULLY AGREE TO THE TERMS BEFORE USING THE APP OR REGISTERING FOR ITS APPLICATION. YOUR OPENING THE APP AND CLICKING ON THE “AGREE” BUTTON AT THE BOTTOM OF THE POP-UP PAGE WILL BE PERCEIVED AS AN INDICATION THAT YOU HAVE ACCEPTED THE TERMS LISTED THEREIN. IF YOU DO NOT AGREE WITH ANY ONE OF THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THIS APP AND IMMEDIATELY DESIST FOM USING IT. PLEASE NOTE THAT THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY DO NOT APPLY TO POSSIBLE LINKS FROM THE APP TO OTHER THIRD-PARTY APPLICATIONS AND SERVICES THAT ARE NOT CONTROLLED, OPERATED OR MAINTAINED BY OURSELVES OR OUR AFFILIATES.
IF YOU HAVE ANY QUESTIONS ABOUT THIS PRIVACY POLICY OR YOU HAVE NOT SEEN YOUR CONCERNS ADDRESSED TO HEREIN, PLEASE CONTACT US BY EMAIL: 13014565707@163.com.
Elephant highly values User privacy. This Privacy Policy details the categories of personal data that Elephant will collect, and how and for what purpose such data will be processed.
During usage by Users of the APP, two basic categories of information of theirs will be collected, namely personal information and non-personal information.
a. Personal information refers to the information provided to the APP when a user registers on the App, uploads content on any part of the APP, participates in a community, or conducts other activities on the APP. This information may enable the APP to identify a user, such as his/her name, email address, telephone number, postal address and contact information.
b. Non-personal information refers to information that does not help to identify a user personally, such location, demographics, app usage, internet tracking and usage information on part of the User.
The personal data to be collected will include the information in relation to the following:
a. The User's Account: Information in relation to the User's account created in the APP, including but not limited to a User's mobile phone number, his/her personal data, such as his photo, nickname, gender, educational background and occupation;
b. The User's Device: The device which he/she uses to access the APP such as his/her computer, laptop or mobile phone, which may include IP address, geographic location, unique device identifiers, the type and language of his/her browser, and transaction information;
c. The User's Contact Information: including his/her name, phone number, email address, physical address, and postal code;
d. Usage data: In order to provide the Users with more accurate customized services, the APP needs to collect, including but not limited to, the User's Android ID, search records, browsing history of pages in the APP and other “traffic data”, such as access time, access date, software crash reports, session identification numbers, and references to the APP; other information about his/her use of the APP; user behavior of programs within the APP, such as comments, questions, submission of answers, etc.;
e. Photos and audio files: Should a User wish to post picture, video or audio files, a request will be made to access to his/her mobile phone photo gallery or recorder;
f. Source IP address/location information: The APP will collect and store the source IP address of the User's device, so that if he/she chooses to enable this feature, the APP can deliver specific information about this positioning based on his (her ) current location;
g. Other information the User provides to the APP: The APP also collects details of the User's communications with Elephant, including interactions with customer support staff, and related content through other social media channels.
The APP may collect personal data about the User from third parties (such as when he/she chooses to use a third-party social platform account to log in to Elephant) and other lawful sources in accordance with his/her instructions. Data from other sources include, but are not limited to, the account information, such as account ID, picture, location and gender, nickname of the User, which the APP will collect when he/she chooses to log in to Elephant using a third-party social platform account (such as Facebook, Twitter, Instagram, WeChat, Weibo, and Google); Information Elephant receives about the User through its offline interactions with the User facilitates the ability of Elephant to update and correct the database of User information to allow Elephant to better tailor user experience on the App.
Generally the personal data collected will be used to:
a. provide, support or upgrade the services of the APP;
b. implement security measures available to the APP, and to ensure that User activities comply with relevant policies and laws.
Additionally, the Users' personal data may be used for other purposes in addition to those listed above with their consent, such as statistics, demographics and analysis of APP users and their usage patterns.
For the above purposes, the personal data of the Users will be shared on a legal, necessary and voluntary basis with service providers, partners, affiliates, developers and publishers of the APP Operator, and other parties a User may instruct. However, the personal data will not be shared with third parties (not controlled by the Operator or its affiliates) for any marketing purposes. The list of the parties with whom the personal data will be shared with is as follows:
I. Service Providers: All personal information mentioned in this Privacy Policy is stored and operated by the APP. The Users' privacy will be respected and their personal information will not be disclosed and their registration information will not be changed without authorization, UNLESS:
i. it is disclosed or changed with express authorization from the User in advance;
ii. it is required by relevant laws and regulations;
iii. it is required by some competent government authorities;
iv. it is required for the protection of public interest.
II. Affiliates and third-party agents: third-party agents, subsidiaries, affiliates, and partners that perform functions on behalf of the APP Operator, such as hosting, content syndication, content management tools, social media integration, marketing, analytics, customer service, fraud prevention, etc. These entities have the access to the personal information of the Users that is necessary to perform their functions and are contractually obligated to maintain the confidentiality and security of the personal information. They will not use, sell, distribute or alter the data in any way other than to provide the APP with required services.
III. Transfer of the data of the Users: While providing applications and services, the APP Operator may change ownership, sell all company assets, or certain other assets associated with the APP and some or all of the information collected by the APP will be automatically transferred to the new operator of the APP that acquires all or part of the assets of the APP Operator, or to another company the APP Operator incorporates
The APP Operator will commit to doing the upmost to ensure the security of the Users' personal information, using administrative, technical and physical safeguards to protect such personal data, and being vigilant about the nature of personal data, data processing and threats. It will continue to improve such protections as to ensure that personal data of Users is always safe.
a. Any information that is provided by a User in public areas (e.g. replies, posts, comments) will be public and available to anyone to access and use. Users are advised to be careful not to post any personal information they wish to keep private.
b. Should a User send or post any offensive, inappropriate or objectionable content on the APP, or otherwise engages in any disruptive activity, his/her personal information will be used by the APP Operator to prevent such conduct, and the APP Operator holds the right to interpret and evaluate the above content. As an example, the APP Operator has defined “inappropriate content” as any content that is related with pornography, gambling, the use or trade of drugs, religious, racial, cultural or discriminatory behavior.
I. A User's personal data is not automatically sold and there is no automatic offer in the APP for the sale of personal data from the User.
II. A User is entitled to the right to request that the APP Operator either
a. discloses the specific personal data the APP operator collects, uses, discloses to other parties, or
b. delete his/her personal data. If the User has an Elephant account, he/she may exercise his/her rights within the relevant functions within the APP through his/her Elephant account, which requires him (her) to be logged into his/her Elephant account. If the User is only a visitor and does not have an account, he (she) can exercise his/her rights by contacting the APP Operator at “13014565707@163.com.” The User may be asked for additional information, such as the User's country of residence, email address, identifying information and phone number, in order to verify the request before it is accepted
III. The User will not be discriminated against in line with his/her rights as listed above.
The interpretation of this Privacy Policy will follow Chinese Law, especially the Law of the People's Republic of China on Personal Information Protection. When this Privacy Policy is promulgated, consideration will be afforded to relevant legislation from United States such as California Consumer Privacy Act and from European Union such as General Data Protection Regulation. However when there is a dispute arising between a User and the APP Operator, China Law will provide the governing framework.
The APP Operator reserves the right to revise all or part of this Privacy Policy at any time and will post a public notification to the Users of the revised part of the Policy. A User's continued use of the APP after the posting means that he/she accepts those revisions. A separate notice of changes or revisions will be sent if the APP Operator intends to make changes or revisions to this Privacy Policy, which are retroactively binding.
The Users are provided with choices to control and manage their personal data collected by the APP, in terms of which Users may:
a. Delete their data: they may ask the APP to clear or delete all or part of their personal data when it is no longer necessary to provide a User with "services".
b. Change or correct data: they may edit some of their personal data through their accounts. In certain circumstances, especially if the data is inaccurate, the User may also ask the APP Operator to change, update or correct his/her data.
c. Object to, limit or restrict the use of data: the User may ask the APP Operator to refrain from using all or part of his/her personal data if the APP Operator does not have the legal right to continue using the data, or restrict the use of the data if his/her personal data is inaccurate or held unlawfully.
d. Claim the right to access and/or obtain their data: The User may request that he/she be provided a copy of his/her personal data and that it be provided in a machine-readable form.
In addition to the using of functions already provided in the APP, the User may make such requests by sending an email to 13014565707@163.com. Also, when he/she closes his/her account, this information will be suspended and deleted from the database of the APP. He/She may also unbind Facebook, Twitter, WeChat, Weibo or Google and delete his/her Elephant account from his/her personal center.