Privacy Policy
Thank you for using the websites, products or services of Beijing ESWIN Computing Technology Co., Ltd. and its affiliates (referred to as “ESWIN Computing”, “we” or “our”). We attach great importance to the protection of personal information. Before sharing any personal information, please make sure you have read and understood this Privacy Policy (“this Policy”). This Policy applies to ESWIN Computing websites, products or services that display or are linked to this Policy.
This Policy mainly explains:
I. How we collect and use the information
II. How we use Cookies
III. How we share, transfer and disclose the information
IV. Your rights in personal information processing activities
V. How we protect and store the information
VI. How we manage minors’ personal information
VII. How the information is transferred globally
VIII. Updates to this Policy
IX. How to contact us
Please note that:
1. This Policy is highly relevant to your usage of our website, products or services. When you are in the process of downloading, installing, starting, browsing, registering, logging in, or using the websites, products, or services concerned, we will collect, process and protect your personal information pursuant to this Policy. Please make sure to read carefully and fully understand this Policy before the usage of the websites. You will be regarded as consent to be bound by all the terms and conditions therein once you click the “Accept” button.
2. The services provided by ESWIN Computing may include or link to a third-party website, product or service. If you choose to use the website, product or service operated by the third-party, they may collect and use your personal information, but not in conformance with the same rules as set forth in this Policy. Please note that this Policy only applies to the personal information you have provided to us, rather than that collected or used by any third party. We recommend that you carefully read and be aware of the pertinent privacy policy, user agreement or practices when using any third-party service, and determine whether to proceed accordingly.
3. If you do not agree with the terms and conditions set forth herein, you may scroll down to the bottom of the page and click “Decline”. When you choose to do so, it means that you will stop using any website, product or service of ESWIN Computing. It should be noted that if you do not click “Decline” and choose to proceed with ESWIN Computing service, it means that you have fully understood and agreed to all the terms and conditions provided in this Policy (including the updated version).
4. Please pay special attention to the contents in bold or other reasonable means we intend to remind you. Such contents may be highly relevant to your rights and interests, or may be easily overlooked.
I. How We Collect and Use Personal Information
i. How we collect personal information
Personal information refers to the information relevant to an identified or identifiable natural person that is recorded electronically or in any other ways, excluding anonymized information. When you use our products and services, or interact with us, we may collect personal information from you. You are not required to provide us with personal information. In some cases, however, if you choose not to share your information, we may not be able to provide relevant products or services for you, or respond to or resolve the issues you have encountered. We will collect and use your personal information only for the purposes set out in this Policy, which may include the following:
1. Information for account registration. When you register for an account, corresponding information is required like account name, password, email address, phone number, etc.
2. Personally identifiable information. When you contact us, submit resume or for related matters, corresponding information is required such as your name, contact details, educational background, work experience, etc. In the case of recruitment, we may collect personally identifiable information through the entrusted third-party human resources system in order to provide better recruitment services. For recruitment purposes, the information collected through a third-party human resources system may involve sensitive information such as financial account, specific identity and undisclosed behavior record. For such information, we will strictly follow the principles of legality, legitimacy and necessity, and ensure that the information collected is for recruitment purposes only and will not be used for any other purpose. You can refuse to provide or authorize the information concerned in your account or the third-party human resources system. However, if you do so, ESWIN Computing may not be able to provide relevant recruitment services for you.
3. Log information. When you use our products or services or view any content provided by ESWIN Computing, the necessary log information will be collected and stored automatically, including but not limited to access time, access path, client IP address and event information (such as error, crash, restart, upgrade), etc.
ii. How we use personal information
We may use your personal information for the following purposes:
1. Account registration. If you are interested in ESWIN Computing products or services, you can sign up for an account. The account can be used to: implement identity verification and permission management to ensure the security when you use the product or service; get in touch with you, send important notifications and things like that. When you sign up for an account, we will collect the personal information you provide, including the account name, password, email, phone number and country or region.
2. Recruitment services. Your personal information, such as name, educational background and work experience, will be used in order to: identify and assess whether you are suitable for the position; ensure compliance with our internal policies; verify your employment eligibility; conduct background investigation; communicate with you; manage, develop or improve the portal; push notifications of new job opportunities that match your situation.
3. We may design, develop, or promote new services based on the data derived from statistical analysis of de-identified or anonymized personal information. Statistics collected will on the use of our services for internal analysis and share with the public or a third-party, but such statistics will not contain any of your personal information.
4. We will inform you separately and obtain your express consent for any use of your personal information beyond the purposes stated in the “How We Collect and Use Your Personal Information”.
II. How We Use Cookies
In order to ensure the normal operations of the website, meet your personalized needs and enable convenient and secure access for you, we will store one or more small data files called Cookies on your computer or mobile device. Generally, Cookies contain identifiers, the site name, numbers and characters. Cookies are specified assigned to you, and can only be read by the host domain that issues the Cookies. We send Cookies to simplify your repeated login steps and store your preference settings to deliver preference settings and help determine your login status and account or data security.
We will not use Cookies for any purpose other than those stated in this Policy. You can manage or delete Cookies according to your preferences. You can clear all Cookies stored on your device. Most Web browsers automatically accept Cookies, but you can usually modify your browser setting to decline Cookies as required. In addition, you can also clear all Cookies stored in the software. However, if you do so, you may need to change the relevant settings every time you access the system, 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.
III. How We May Share, Transfer and Disclose Personal Information
i. Sharing
We will not share your personal information with any companies, organizations or individuals other than ESWIN Computing, except for the following circumstances:
1. Your express consent or permission has been obtained in advance;
2. Applicable laws and regulations, legal procedural requirements, mandatory law enforcement or judicial requirements;
3. Other circumstances where applicable laws and regulations permit us to share your personal information.
With your consent, we may share your information with our affiliated party. However, only necessary personal information will be shared, and it is bound by the purposes stated in this Policy. When sharing your information, we will, in accordance with the requirements of applicable laws, inform you of the recipient’s personal information, the purpose of information processing, the processing method, the type of information shared and other necessary information, and seek your consent. If our affiliates want to change the purpose of information processing, they will ask for your consent separately.
ii. Transfer
We will not transfer your personal information to any companies, organizations or individuals, except for the following circumstances:
1. Your express consent or permission has been obtained in advance;
2. Applicable laws and regulations, legal procedural requirements, mandatory law enforcement or judicial requirements;
3. In case of any merger, acquisition, asset transfer or similar transaction, if information transfer is involved, we will require the new company, organization or individual that holds your information to comply with this Policy. Otherwise, we will require the company, organization or individual to seek your consent separately.
iii. Disclosure
We will disclose your information only under the following conditions and take security safeguards in alignment with industry standards:
1. According to your needs, disclose your designated personal information in the manner to which you explicitly agree with;
2. If it is necessary to provide your information in accordance with the requirements of laws and regulations, mandatory law enforcement or judicial requirements, we may disclose your personal information according to the type of information requested and the manner of disclosure. In compliance with laws and regulations, we will require the recipient to issue corresponding legal documents, such as subpoenas or investigation letters when we receive the above request for disclosure of information. We will carefully review all requests to ensure that they are legally valid and are limited to the data that law enforcement agencies have obtained for their specific legal purposes. To the fullest extent permitted by applicable laws and regulations, the documents we disclose are protected by encryption keys.
IV. Your Rights in Personal Information Processing Activities
In accordance with applicable laws and regulations, you have the following rights:
(1) The right to be informed of how your personal information is processed;
(2) The right to access, review, or replicate your personal information held by us;
(3) The right to request us to update or correct any inaccurate information;
(4) The right to object to or restrict our use of your personal information;
(5) The right to request us to delete your personal information;
(6) The right to request us to explain the information processing rules;
(7) The right to personal information portability pursuant to applicable laws and regulations;
(8) If allowed by applicable laws, you have the right to withdraw your consent at any time when we process your personal data based on your consent. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal information based on your consent before the withdrawal; nor does it affect any data processing based on another justification other than your consent;
(9) Other rights prescribed by applicable laws and regulations.
In addition to exercising your rights in the ways stated in this Policy, you can also reach out to us directly, and we will reply to your questions about the exercise of your rights. For security purposes, we may ask you to provide a written request or your identity document. We will respond to your request within a reasonable period of time. We do not charge a fee in principle, but for repetitive requests beyond the reasonable limit, we may charge a certain cost as appropriate. We may reject requests that are unreasonably repetitive or that require excessive technical effort (for instance, require the development of a new system or fundamentally change in existing practices). In addition, we may not respond to requests that may cause serious damage to the legitimate rights and interests of other individuals or entities. If we refuse to comply with your request, we will explain the reasons why.
V. How We protect and Store Personal Information
i. How we protect personal information
We attach great importance to the security of personal information. We use strict security systems and appropriate physical, management and technical safeguards in line with industry standards to protect your personal information from unauthorized access or disclosure, use, modification, damage, or loss. The specific measures are as follows: (1) We use cryptographic technologies to ensure data confidentiality; (2) We put in place protection mechanisms to prevent data from attacks; (3) We exercise access controls to permit only authorized access to your personal information; (4) We provide training on personal information protection to increase employee awareness of personal information protection; and (5) We regularly update and disclose relevant information such as reports on security risks and personal information impact assessments.
The internet is not 100 percent secure, but we will do our utmost to ensure the security of the personal information you provided. In the event that any damage to our physical, technical or management safeguards results in unauthorized access to and disclosure, tampering or destruction of your personal information and damage to your legitimate rights and interests, we will assume the corresponding legal responsibility. Due to technical limitations and various potential malicious means, it is impossible to guarantee the absolute security of information, even if we do our best to reinforce our security safeguards. In case of a security incident, we will immediately inform you of the following in accordance with applicable laws and regulations: The general situation and possible impact of the security incident, the measures we have taken or will take, suggestions on how to prevent or reduce risks, and remedial measures for you, etc. We will promptly notify you of the information regarding the incident through email, letter, telephone, push notification, etc. If it is difficult to inform the affected users one by one, we will publish an announcement in a reasonable and effective manner.
ii. How we store personal information
1. Storage region. We store users’ personal information within the territory of the People’s Republic of China (“China”) in accordance with applicable laws and regulations. If cross-border storage is needed, we will seek your consent separately according to applicable laws and regulations.
2. Storage period. Unless otherwise prescribed by applicable laws and regulations, we will retain your personal information in the shortest possible time to provide corresponding services or achieve processing purposes, except that you ask us to delete or cancel your account immediately or otherwise specified by laws and regulations. Please note that as to the storage and processing of anonymized or de-identified information, we do not need to seek your consent or inform you of it.
VI. How We Manage Minors’ Personal Information
Our websites, products and services are primarily intended for adults. Minors should not create their own personal account without the consent of a parent or guardian. If a minor’s personal data is collected with prior parental consent, we will only use or disclose the data as permitted by law, with the explicit consent of the minor’s parent or guardian, or when necessary for the protection of the minor.
We will ensure the confidentiality and security of minors’ information pursuant to applicable laws and regulations. If we accidentally collect a minor’s personal information under the age of 16 without verified consent from the minor’s guardian, we will delete relevant data as soon as possible. If you are the guardian of a minor under the age of 16 and have any questions about the use of our products or services by the minor or the user information provided to us, please contact us in time.
VII. How Personal Information is Transferred Globally
i. Personal information collected and generated within the territory of China
In principle, the personal information collected and generated within the territory of China shall be stored within China. Because we provide products or services through resources and servers around the world. It means that upon your authorization and consent, your personal information may be transferred to or accessed from overseas jurisdictions in the country/region where you use the products or services. If personal information truly needs to be provided to any jurisdiction outside the territory of China for business needs, we will ensure that any of the following conditions shall be met:
(1) Pass the security assessment organized by the Cyberspace Administration of China (CAC) has been passed;
(2) Conduct personal information protection certification by professional institution according to the provisions of the Cyberspace Administration of China (CAC);
(3) Enter into a contract with the overseas recipient based on the standard contract formulated by the Cyberspace Administration of China (CAC), and specify both parties’ rights and obligations;
(4) Other conditions stipulated by laws or administrative regulations or by the Cyberspace Administration of China (CAC).
Some jurisdictions may have different data protection laws or even no applicable legislation. In such circumstances, we will take necessary measures to ensure that personal information processing activities of the overseas recipient meet the personal information protection standards stipulated by Chinese laws. For example, we will take security measures such as de-identification before cross-border transferring personal information.
If we need to provide your personal information to any party outside the territory of China, we will inform you of the overseas recipient’s title or name, contact information, processing purposes, processing methods, category of personal information, the methods of and procedures for your exercise of rights specified in law over the overseas recipient, and obtain your consent separately. Before providing personal information to any party outside the territory of China, we will conduct an impact assessment on the protection of personal information and record the processing.
ii. Personal information collected and generated outside the territory of China
For personal information collected and generated outside the territory of China, we will comply with applicable data protection regulations for cross-border data transfers, such as the EU General Data Protection Regulation (“GDPR”). To ensure that your personal information is adequately protected, we will take necessary security measures for cross-border data transfers and comply with applicable data protection laws.
VIII. Updates to This Policy
ESWIN Computing reserves the right to update or modify this Policy at any time. In case of any changes, we will release the latest Privacy Policy in a timely manner. If major changes are made to the Privacy Policy, we may notify you through different channels, for example, posting a notice on our website or issuing separate notices to you.
IX. How to Contact Us
If you have any questions, comments or suggestions regarding this Policy or your personal information, or if you want us to update your information, please send an email to branding@eswincomputing.com, or call us at 010-67816000-1006. Generally, we will get back to you within 30 working days.
If you are not satisfied with our reply or the way we handle your personal information as per this Policy, you have the right to complain or report to the relevant data protection authority or a court of competent jurisdiction. If you live in China, you have the right to file a lawsuit in the competent people’s court where Beijing ESWIN Computing Technology Co., Ltd. is located. If you live in the European Union, a list of national data protection authorities can be found here: http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm.
This Policy was released and took effect on July 28, 2022.
