SCI Privacy Policy

Latest update: October 31,2021

• Sublime China Information Co., Ltd. (hereinafter referred to as “SCI” or “we”) is committed to protecting the security of your personal information and maintaining your trust in SCI, abiding by the principles of legality and fairness, minimum necessity, openness and transparency. At the same time, SCI promises to adopt corresponding security protection measures to protect your personal information in accordance with the mature security standards of the industry.

• The Privacy Policy of SCI (hereinafter referred to as the “Privacy Policy”) applies to all products or services of SCI. If a product has a separate privacy policy, the privacy policy of that product has priority. For the content not covered by the product privacy policy, this general Privacy Policy shall prevail.

If you have any questions, comments or suggestions, please contact us at:
Email: overseas.info@sci99.com
Tel: +86-533-5075233

• This Privacy Policy will help you understand the following:
I. How we collect and use your personal information
II. How we protect your personal information
III. How we use cookies and similar technologies
IV. How we share, transfer and publicly disclose your personal information
V. Your rights
VI. How we update this Privacy Policy
VII. How to contact us

I. How we collect and use your personal information

According to the Personal Information Protection Law of the People’s Republic of China, personal information is a variety of information related to identified or identifiable natural persons recorded electronically or by other means, excluding anonymized information. SCI will only collect necessary information to realize product functions or services in accordance with the principles of lawfulness, fairness, minimum necessity, and openness and transparency. We will collect your information based on the following conditions:

i. Help you register as our user
In order to complete the account registration, you need to provide the following information: your mobile phone number, user name and password. We collect this information to help you successfully complete the registration process and provide you with a continuous and stable product or service specific to the registered account. ii. Provide you with products and services
(i). When you use our products or services, we will collect the following information:
A. In order to protect your account security, we will collect your device information. For example, your device model, operating system version, unique device identifier (IMEI, network device hardware address MAC) and device connection information (IP address). We collect this information to prevent malicious programs and respond to security risk control requirements such as anti-cheating, anti-fraud, and illegal information control.
B. When you use our products, our server will automatically record some information and generate log information, including the information about the products and the contents you browse, the date, time, and duration of access to the service, etc. We collect this information only for data statistics and analysis to improve the quality of our products and services.
C. When you purchase our products or services, we need to collect the following information according to the types of products or services, including information about the transaction product or service, transaction amount, order time, order number, order status, payment method, payment account, payment status, etc. We collect this information to help you complete the transaction smoothly, protect your transaction security and provide corresponding products or services.
D. When you participate in our activities, such as lucky draw and questionnaire surveys, you may be required to submit relevant information. For example, your personal identity information and mailing address (used for mailing gifts). We collect this information only for the purpose of activities, and your opinions will help SCI with data analysis and products or services improvement.
E. When you interact with our customer service over the phone, for the security of your account, we may need you to provide account information and your personal information to verify your identity, such as your own identity information and contact information. We collect this information to investigate the facts and help you solve the problems.
(ii). Please know and understand that we cannot obtain the personal information you provide to external third parties (except for the subsidiary of SCI), or the personal information collected by external third parties, and we will not use unconventional methods to obtain your personal information without authorization. If we need to collect your personal information from third-party partners for our business development, we will clearly indicate to you the source, purpose, method and scope of authorization to share your personal information before collection. Please read carefully the User Agreement or Privacy Policy of the third-party partner services.
(iii). In order to better provide you with products and services, during your subscription to this product, we may need to obtain some of your sensitive personal information. Before collecting such information, we will explain to you the purpose, method and scope of use of the collection, and obtain your consent separately.
According to the Personal Information Protection Law of the People’s Republic of China, sensitive personal information is personal information that, once leaked or illegally used, can easily lead to the infringement of the personal dignity of natural persons or the harm of personal and property safety, including information regarding biometrics, religious beliefs, specific identity, medical health, financial accounts, whereabouts, as well as personal information of minors under the age of fourteen.
3) The above-mentioned personal information you provide will continue to be authorized to us during your subscription to this product or service. When you close your account, we will stop using the above information. After your account is closed or the service expires, the above information will be kept for at least three years in accordance with the requirements of the Civil Procedure Law, the Electronic Commerce Law and other relevant laws and regulations.
The personal information you provide will be stored within the People’s Republic of China. If we need to provide it overseas, we will inform you of the name of the overseas recipient, contact information, processing purpose, processing method, types of personal information, and the methods and procedures for individuals to exercise their rights to overseas recipients, etc., and obtain your consent separately.
When we want to use the above personal information for other purposes not specified in this Privacy Policy, we will ask for your consent in advance. When we want to use the information collected for a specific purpose for other purposes, we will also ask for your consent in advance.

iv. Exceptions
Under the following cases, we do not ask for your consent to collect and use your personal information:
(i) When it is directly related to national security and national defense security.
(ii) When it is directly related to public safety, public health and major public interests.
(iii) When it is directly related to litigation, arbitration, enforcement and other legal procedures; or when it is in accordance with the requirements of laws and regulations, administrative agencies, public prosecutions and other agencies.
(iv) When it is in an emergency and it is necessary to protect your or other individuals’ life, property and other major legal rights, but it is difficult to obtain the consent of the person.
(v) When the personal information is disclosed to the public by yourself or collected by us from legally publicly disclosed channels.
(vi) When the personal information is necessary for the conclusion and performance of contracts.
(vii) Other cases related to our fulfillment of the obligations stipulated by laws and regulations.

II. How we protect your personal information

i. We have used safety protection measures that comply with industry standards to protect the personal information you provide in order 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. For example, we will deploy an access control mechanism to ensure that only authorized personnel can access personal information; and we will organize security and privacy protection training courses to strengthen employees’ awareness of the importance of protecting personal information. Authorized personnel are bound by confidentiality obligations. If they fail to comply with these obligations, they will be subject to corresponding penalties including termination of the contract and criminal prosecution.

ii. SCI’s data security capabilities: SCI has set up a Network Information Security Department, which is specifically responsible for the data security, and protects SCI’s data and customer information from being illegally obtained; SCI has formulated complete data security system specifications and procedures; Bastion hosts and application firewalls are installed to effectively prevent external and internal intrusions; with a deep understanding of network hardware, application platforms and operating systems, members of the Network Information Security Department are capable of handling unexpected external security incidents.

iii. SCI will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. SCI will only retain your personal information for the period required to achieve the purpose stated in the Privacy Policy, unless it is necessary to extend the retention period or it is permitted by law.

iv. The Internet is not an absolutely secure environment. Meanwhile, e-mails, instant messages and communication with other SCI’s users are not encrypted. SCI strongly recommends that you do not send personal information through such methods. Please use a complex password to assist us to ensure the security of your account.

v. As the Internet environment is not 100% secure, we will try our best to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, destruction of information or damage to your legitimate rights and interests, we will bear the corresponding legal responsibility.

vi. If a personal information security incident occurs unfortunately, we will promptly inform you the following information in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to independently prevent and reduce risks, remedial measures for you, etc. We will promptly inform you about the incident by e-mail, letter, telephone, notification, etc. If it is difficult to inform each individual one by one, we will take a reasonable and effective way to issue an announcement. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

vii. Regarding children’s personal information, children are not allowed to create their own user accounts without the consent of their parents or guardians. For the collection of children’s personal information with parental consent, we will only use or publicly disclose this information when it’s permitted by law, the parent or guardian’s explicit consent, or when it is necessary to protect the child. Although local laws and customs have different definitions of children, we treat anyone under the age of 14 as a child. If we find that we have collected children’s personal information without obtaining verifiable parental consent in advance, we will try to delete the relevant data as soon as possible.

III. How we use cookies and similar technologies

i. Cookies
To ensure the normal operation of the website, we will install small data files called cookies on your computer or mobile devices. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of cookies, websites can store your preferences. We will not use cookies for any purpose other than those described in this Privacy Policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer, and most browsers have a function to block cookies. But if you do this, you need to personally change the user settings each time you visit our website.

ii. Similar technologies
(i) User behavior analysis script. It is used to collect your activities on the website to optimize your experience and provide you with better services.
(ii) Web beacons and pixel tags (if any). We may use other similar technologies on our website, such as web beacons and pixel tags. Web beacons are usually transparent images embedded in websites or e-mails. With the help of the pixel tag in the e-mail, we can know whether the e-mail has been opened. If you don't want to track your activities in this way, you can notify us by phone or e-mail to unsubscribe.
(iii) DoNotTrack (if any). Many web browsers have a DoNotTrack (Do Not Track) function, which can post DoNotTrack requests to websites. Currently, major Internet standard organizations have not formulated relevant policies to regulate how websites should respond to such requests. But if DoNotTrack is enabled in your browser, all our websites will follow your settings.

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

i. Share
We will not share your personal information with any company, organization or individual other than SCI, except in the following cases:
(i) Sharing with other parties: Only with your explicit consent, we will share your personal information with other parties.
(ii) We may share your personal information externally in accordance with laws and regulations, or mandatory requirements of government regulatory agencies.
(iii) Sharing with our subsidiaries: Your personal information may be shared with the subsidiaries of SCI. We will only share necessary personal information and are bound by the purpose stated in this Privacy Policy. If our subsidiary wants to change the purpose of processing personal information, we will ask for your authorization and consent again.
(iv) Sharing with authorized partners: Only for the purpose stated in this Privacy Policy, some of our services will be provided by authorized partners. We may share some of your personal information with our authorized partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and will only share necessary personal information to related services. Our partners have no right to use the shared personal information for any other purpose.
For the company, organization and individual with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to handle personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.
(v) 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. Since we provide products or services via resources and servers all over the world, it means that, after obtaining your authorized consent, your personal information may be transferred to the overseas jurisdiction of the country/region where you use the product or service, or you may receive visits from these jurisdictions. Such jurisdictions may have different data protection laws or even no relevant laws. In such cases, we will ensure that your personal information is sufficiently and equally protected within the territory of the People’s Republic of China.

ii. Transfer
We will not transfer your personal information to any company, organization or individual other than SCI, except in the following cases:
(i) Transfer under explicit consent: With your explicit consent, we will transfer your personal information to other parties.
(ii) When it involves a merger, acquisition or bankruptcy liquidation, we will require the new company or organization that holds your personal information to continue to be bound by this Privacy Policy if it involves the transfer of personal information, otherwise we will require the company or organization to ask for your authorization and consent again.

iii. Publicly disclosure
We will only publicly disclose your personal information in the following cases:
(i) With your explicit consent;
(ii) Based on the mandatory requirements of laws and regulations, legal procedures, litigation or government regulatory agencies;

iv. Exceptions for obtaining prior consent when sharing, transferring, and publicly disclosing your personal information.
Without your consent, we will not share, transfer or publicly disclose your personal information to third parties, except in the following cases:
(i) It is directly related to national security and national defense security.
(ii) It is directly related to public safety, public health, and major public interests.
(iii) It is directly related to litigation, arbitration, enforcement and other legal procedures; or in accordance with the requirements of laws and regulations, administrative agencies, public prosecutors and other agencies.
(iv) In an emergency, it is necessary to protect the life and property of you or other individuals, but it is difficult to obtain the consent of the person.
(v) Personal information is disclosed to the public by you or collected by SCI via legal public disclosure channels.
(vi) Personal information is necessary for the conclusion and performance of contracts.
(vii) Other cases related to our fulfillment of the obligations stipulated by laws and regulations.

V: Your rights

In accordance with China’s relevant laws, regulations and standards, as well as common practices in other countries and regions, we guarantee that you exercise the following rights with respect to your personal information:

i. Access your personal information
You have the right to access your personal information, except for exceptions stipulated by laws and regulations. If you want to exercise data access rights, you can access it in the following ways:
Account information - If you want to modify the personal information and password in your account, you can contact your account manager for modification.
If you want to modify your personal information, you can also contact us via phone or e-mail. After verifying your identity, we will respond to your modification request within 10 working days. As long as we do not need to spend manpower and material resources too much, we will provide you with other personal information generated during your use of our products or services. If you want to exercise data access rights, please contact us via e-mail or other means.

ii. Correct your personal information
When you find that the personal information we process is wrong, you have the right to ask us to make corrections. You can apply for correction by phone or e-mail. After verifying your identity, we will respond to your correction request within 10 working days.

iii. Delete your personal information
In the following cases, you can request us to delete your personal information:
(i) If our treatment mode violates laws and regulations.
(ii) If we collect and use your personal information without your consent.
(iii) If our treatment mode of personal information violates our agreement with you.
(iv) If you no longer use our products or services, or you unsubscribe your account.
(v) If we no longer provide you with products or services.
If we decide to respond to your deletion request, we will also notify the entity that has obtained your personal information from us and require them to delete timely, unless laws and regulations provide otherwise, or these entities obtain your independent authorization.
When you request to delete information from our service, we will delete the corresponding information as soon as possible in accordance with the requirements of laws and regulations, but some information may not be completely deleted due to technical reasons. When it cannot be deleted, we promise to stop processing except storing and taking necessary safety protection measures, unless otherwise stipulated by laws and regulations.

iv. Change the scope of your authorization and consent
Some basic personal information is required to complete each business function. For the collection and use of additional personal information, you can give or withdraw your authorization and consent at any time by telephone or e-mail.
When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous processing of personal information based on your authorization.
If you don't want to receive the commercial advertisement we send you, you can cancel it at any time by telephone or e-mail.

v. Cancel your personal information account
You can notify us to cancel the previously registered account by customer service phone or e-mail. After canceling the account, we will stop providing you with products or services and delete the corresponding information as soon as possible in accordance with the requirements of laws and regulations, but some information may not be completely deleted due to technical reasons. When it cannot be deleted, we promise to stop processing except storage and take necessary safety protection measures, unless otherwise stipulated by laws and regulations.

vi. Obtain a copy of your personal information
You can notify us by phone or email to obtain a copy of your personal information.
On the premise of technical feasibility, such as data interface matching, we can also directly transmit your personal information copy to the third party designated by you according to your requirements.

vii. Restrict the automatic decision-making of information system
In some business functions, we may only make decisions based on non-manual automatic decision-making mechanisms such as information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for explanation, and we will also provide appropriate remedies.

viii. In response to your requests above
To secure your account, you may need to provide a written request or otherwise prove your identity. We will ask you to verify your identity before processing your request.
We will reply within 10 working days.
In principle, we will not charge for your reasonable request, but we will charge a certain cost for repeated requests that exceed the reasonable limit. We may refuse requests that are unreasonably repeated, require too many technical means (e.g., developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are very impractical (e.g., involving information stored on backup tapes).
We will not respond to your request in accordance with laws and regulations in the following cases:
(i) It is directly related to national security and national defense security.
(ii) It is directly related to public safety, public health and major public interests.
(iii) It is directly related to litigation, arbitration, enforcement and other legal procedures; or violating the requirements of laws and regulations, administrative organs or public security organs.
(iv) There is sufficient evidence that you have subjective malice or abuse of power.
(v) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations.
(vi) It involves trade secrets.

VI. How we update this Privacy Policy

In order to provide you with better service, we will update the terms of this Policy according to the update of products and the requirements of laws and regulations. Without your specific consent, we will not reduce your rights under this Privacy Policy. We will post any changes to this Privacy Policy on this page.

For major changes, we will also provide more significant notices (For some services, we will send notices by e-mail to explain the specific changes in the Privacy Policy).

Major changes refer to in this privacy policy include but are not limited to:
(i) Significant changes in our service model, such as the processing purpose and processing method of personal information, the type of personal information processed, storage period, etc.
(ii) Significant changes in ownership structure, organizational structure, etc., such as owner changes caused by business adjustment, bankruptcy, M & A, etc.
(iii) Changes in the main objects of personal information sharing, transferring or public disclosure.
(iv) Significant changes in your right to participate in personal information processing and the way in which you exercise it.
(v) Changes in the department responsible for handling personal information security, contact information and complaint channels.
(vi) When the personal information security impact assessment report indicates that there is a high risk.

We will also archive older versions of this Privacy Policy for your reference.

VII. How to contact us

If you have any questions, comments or suggestions about this Privacy Policy, you can contact us by telephone or email.

We have set up a special department for personal information protection, which you can contact through the following e-mail address: itservice@sci99.com. Generally, we will reply within 10 working days.

If you are not satisfied with our reply, especially when our personal information processing behavior has damaged your legitimate rights and interests, you can also complain or report to the Network Information Bureau, Telecommunications Bureau, Public Security Bureau, Industry and Commerce Bureau and other regulatory departments.