Capital XII Co., Limited "CapitalXII" system


Privacy Protection Guidelines


Introduction


Welcome to use the "CapitalXII" system.


We attach great importance to protecting your personal information and privacy. You can learn about our collection, use, and storage of user personal information, as well as your relevant rights, through the "Capital XII Co., Limited" CapitalXII "System Privacy Protection Guidelines. Please carefully read and fully understand the relevant content:


1、 We will explain one by one the types of personal information we collect about you and their corresponding purposes, so that you can understand the specific categories, reasons for use, and collection methods of personal information we collect for a specific function.


2、 When you use certain functions, we will collect your sensitive personal information with your consent (unless it is necessary to collect according to relevant laws and regulations). If you are using the onboarding application function, we will collect your personal basic information. Refusing to provide the above information will only prevent you from using the relevant specific functions, but will not affect your normal use of other functions of the "CapitalXII" system.


3、 We will not proactively share or transfer your personal information to any third party outside of CapitalXII Inc. or the company you work for.


If there are other situations where you need to share or transfer your personal information, we will directly obtain or confirm that a third party has obtained your explicit consent for the above actions, except as otherwise provided by laws and regulations or necessary to protect user rights or protect the ecological security of the "CapitalXII" system. In addition, we will conduct a risk assessment on the behavior of "providing information to the public".


4、 We will not proactively obtain your personal information from third parties outside of CapitalXII Inc. If it is necessary to obtain your personal information from a third party for business development, we will verify the legality of the source in accordance with the law, or clarify the source, type, and scope of use of personal information to you before obtaining it. If the personal information processing activities required by the "CapitalXII" system for conducting business exceed the scope of authorization and consent you originally provided to a third party, we will obtain your explicit consent before processing your personal information; In addition, we will strictly comply with relevant laws and regulations, and require third parties to ensure the legality of the information they provide.


5、 If you would like to learn more detailed information, please read the corresponding chapters according to the following index:


1. How do we collect and use your personal information


2. How do we save your personal information


3. How do we protect your personal information


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


5. How do you manage your personal information


6. How to update this privacy protection guide


7. How do we handle personal information of minors


8. Others


9. Contact Us


1. How do we collect and use your personal information


During your use of the "Capital XII" system services, we will collect and use your personal information in the following ways:


When you register for the "Capital XII" system account, we will collect and use your nickname, avatar, phone number, and login password. We collect the above information from you to help you complete the registration of your "Capital XII" system account and use functions such as employment application, salary, and hour confirmation to protect the security of your "Capital XII" system account. Collecting and using mobile phone numbers is to meet the requirements of relevant laws and regulations for authenticating true identity information. If you do not provide such information, we will not be able to create an account for you and provide services to you normally.


1.2 When you use the onboarding application function, in order to help you fill out the onboarding application information more quickly, we will collect and use your onboarding application information; To facilitate your salary payment, we will collect your bank card information. You can request us to destroy your personal information after one year of resignation (according to relevant regulations, employment information should be kept for at least one year).


1.3 If you contact our customer service, we may need you to provide necessary personal information for identity verification to ensure the security of your account. To provide services based on your request, with your authorization, human customer service personnel need to query or verify your relevant information within the scope of your authorization. We will take technical and management measures as much as possible to ensure the security and confidentiality of your information, and use it within the necessary scope. We may also save your contact information (phone number, WeChat account, QQ number, or other contact information you use or proactively provide), your communication records and content with us, and other necessary information to provide and record customer service for you.


1.4 In addition, according to relevant laws, regulations, and national standards, in the following situations, we may process your relevant personal information without seeking your authorization and consent:


a) Necessary for personal information processors to fulfill legal obligations or responsibilities;


b) Necessary for the conclusion and performance of the contract to which you are a party;


c) Necessary for responding to sudden public health emergencies or in emergency situations to protect the life, health, and property safety of natural persons;


d) Process personal information that you have publicly disclosed or other legally disclosed within a reasonable range in accordance with the law;


e) Other situations stipulated by laws and administrative regulations.


1.5 Please understand that the functions and services we provide to you are constantly updated and developed. If a certain function or service is not informed of the processing rules for collecting and using your information in the aforementioned instructions, we will inform you of the scope, purpose, and method of information collection through page prompts, interactive processes, website announcements, and other means to obtain your consent.


1.6 If we use your personal information beyond the purpose authorized by you and to the extent that it is directly or reasonably related, we will inform you again and obtain your explicit consent before using your personal information.


1.7 Please note that currently, the "CapitalXII" system will not proactively obtain your personal information from third parties outside of CapitalXII Inc. If in the future, it is necessary to indirectly obtain your personal information from a third party for business development, we will clarify the source, type, and scope of use of your personal information before obtaining it. For example, if the personal information processing activities required by the "CapitalXII" system for conducting business exceed the scope of your original authorization and consent when providing personal information to a third party, we will obtain your explicit consent before processing your personal information.


In addition, we will strictly comply with relevant laws and regulations, and require third parties to ensure the legality of the information they provide.


2. How do we save your personal information


2.1 Location of information storage


We will store the personal information of users collected within China in accordance with laws and regulations. For the purpose of this privacy protection guideline, "within China" does not include the Hong Kong, Macao, and Taiwan regions of China, except for the following situations:


(1) There are clear provisions in the law;


(2) Obtain your explicit authorization;


(3) You request personal initiative such as obtaining overseas services.


If your personal information storage location is transferred from within China to overseas, we will strictly comply with legal provisions.


2.2 Duration of Information Storage


Generally speaking, we only retain your personal information for the time necessary to achieve the purpose and for the shortest retention period specified by laws and administrative regulations, such as:


Mobile phone number: Whether you are registering through a mobile phone number or authorized to register an account through a WeChat account, if you need to use the "CapitalXII" system service, we need to always save your mobile phone number (including the initial registered phone number, bound phone number, etc.) to ensure your normal use of the service. After you cancel your account, we will legally delete the corresponding information after the retention period.


When our products or services cease operation, we will notify you through push notifications, announcements, and other forms, and delete your personal information or anonymize it within a reasonable period of time. (The term 'anonymization' in this guideline refers to the process of using technical processing of personal information to make the subject of the personal information unrecognizable and the processed information unrecoverable. The information obtained from anonymization of personal information does not belong to personal information.)


3. How do we protect your personal information


We attach great importance to personal information security and take all reasonable and feasible measures to protect your personal information:


3.1 We have adopted industry-wide data protection technologies and management measures, such as network isolation, data encryption, and employee access control, to prevent unauthorized access, disclosure, tampering, loss, or destruction.


3.2 Please be aware that although we will do our best to ensure or guarantee the security of any information you send us, the internet environment is not 100% secure, and we are not responsible for any risks or losses arising from or related to it.


3.3 In the event of an unfortunate personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly inform you of the relevant situation of the event through application push, email, SMS, phone, and other means. If it is difficult to inform the personal information subject one by one, we will take reasonable and effective measures to publish an announcement. At the same time, we will also proactively report the handling of personal information security incidents in accordance with regulatory requirements.


We will do our best to protect your personal information. We also ask you to understand that no security measures can be flawless.


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


4.1 Entrusted processing


We will entrust a third-party service provider to process the personal information we collect from you, in order to provide us with infrastructure technology, data analysis, marketing decisions, and other products or technical support. The above-mentioned entrusted processing behavior is subject to the stated purpose in this policy, and we will supervise the entrusted third-party service provider in a contractual manner.


4.2 Sharing


(1) Obtain your explicit consent or authorization in advance, or request us to share your personal information with third parties through email or other means;


(2) Provide in accordance with applicable laws and regulations or mandatory requirements from government authorities;


(3) Sharing with our affiliated companies: We may share your personal information with our affiliated companies; However, we will only share necessary personal information and are bound by the stated purposes in this policy; Affiliated companies will also adopt equivalent security measures in accordance with this policy to ensure the security of your personal information;


4.3 Transfer


We will not transfer your personal information to any company, organization, or individual. However, in cases involving mergers, acquisitions, asset transfers, or bankruptcy liquidation, if personal information transfer is involved, we will inform you of the relevant situation and request that the new company or organization holding your personal information continue to be bound by this policy. Otherwise, we will require the company or organization to obtain your authorization and consent again.


4.4 Public Disclosure


Unless otherwise agreed in this contract or explicitly stipulated by law, we will not publicly disclose your personal information.


4.5 Exceptions


In addition, according to relevant laws and national standards, in the following situations, we may share, transfer, or publicly disclose personal information without obtaining your prior authorization and consent:


(1) Related to our obligations under laws and regulations;


(2) Directly related to national security and national defense security;


(3) Directly related to public safety, public health, and major public interests;


(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments;


(5) For the purpose of safeguarding the significant legitimate rights and interests of personal information subjects or other individuals, such as life and property, but it is difficult to obtain my authorization and consent;


(6) Personal information disclosed by the personal information subject or guardian to the public on their own;


(7) Collecting personal information from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels.


4.6 Please note that the information you voluntarily share or even publicly share when using our services may involve personal information or even sensitive information of you or others. Please share or disclose with caution. If the information involved contains personal information from others, please obtain their consent before sharing or disclosing it.


4.7 Please be aware that according to legal regulations, if we take technical and other necessary measures to process personal information, which makes it impossible for the data recipient to re identify a specific individual and cannot be restored, the sharing, transfer, and public disclosure of the processed data do not require separate notification to you and your consent.


5. How do you manage your personal information


During your use of the "CapitalXII" system, you can contact us through the corresponding page prompts or the methods specified in this privacy protection guide to access, correct, delete your personal information, and exercise the right to change the scope of authorization consent and cancel your account. Your opinions will be promptly processed.


5.1 Accessing and correcting your personal information


If you wish to access or correct your personal information, you can click on "[avatar]" and follow the prompts on the page, or you can contact us through the methods specified in this privacy protection guide. We will respond to your request in a timely manner.


5.2 Deleting Your Personal Information


In the following situations, you can request us to delete personal information through the methods specified in this privacy protection guide:


(1) We collect and use personal information in violation of laws, administrative regulations, or agreements with you;


(2) If we violate laws, administrative regulations, or agreements with you to share or transfer your personal information with a third party, we will immediately stop the sharing or transfer behavior and notify the third party to delete it in a timely manner;


(3) If we violate laws, administrative regulations or agreements with you by publicly disclosing your personal information, we will immediately cease the act of public disclosure and issue a notice requiring the relevant recipient to delete the corresponding information;


(4) You no longer use our products or services, or you cancel your account, or we terminate our services and operations.


5.3 Change the scope of your authorization and consent


You can contact us through device permission settings or the methods specified in this privacy protection guide to change the scope of consent or revoke your authorization.


Please understand that the 'CapitalXII' system may need to enable some permissions and collect necessary personal information in order to be implemented. When you withdraw your consent, we will not be able to continue providing you with the services corresponding to the withdrawal of consent, but it will not affect the personal information processing services previously carried out based on your authorization.


6. How to update this privacy protection guide


Our privacy protection guidelines may change in due course. We will publish any changes made to this privacy protection guideline on this page. For significant changes, we will also provide more significant notifications (we may explain the specific changes to our privacy policy through special prompts on the browsing page, etc.). Without your explicit consent, we will not reduce your rights under this privacy policy.


The significant changes referred to in this privacy protection guideline include but are not limited to: significant changes in our service model; Changes in the main objects of personal information sharing, transfer, or public disclosure; Your right to participate in personal information processing and the way you exercise it have undergone significant changes; Our contact information and complaint channels have changed; When the personal information security impact assessment report indicates a high risk.


We will also archive the old version of this privacy protection guide for your reference.


7. How do we handle personal information of minors


We attach great importance to the protection of personal information of minors. According to relevant laws and regulations, the collection and use of personal information of minors under the age of 14 requires authorization and consent from their guardians; The collection and use of personal information of minors who have reached the age of 14 but have not yet reached the age of 18 can be authorized by the guardian or by their own authorization.


If you are a minor (especially a minor under the age of 14), we request that your parents or other guardians carefully read this privacy protection guide and use our services or provide information to us with the authorization and consent of your guardians.


If you are the guardian of a minor, please pay attention to whether the minor you are monitoring has used our products or services with your authorized consent. If you have any questions about the personal information of the minors you are monitoring, please contact us through the methods specified in this privacy protection guide.


8. Others


Under certain specific services or functions of the "CapitalXII" system, we may also inform you of the purpose, method, or scope of processing personal information through interactive copywriting, product interfaces, or pop-up windows. If the content otherwise notified is inconsistent with this guideline, the content otherwise notified shall prevail.


Capital XII Co., Limited