Your trust is very important to us, and we understand the importance of your personal information, and we will take appropriate security measures to protect your personal information and privacy in accordance with laws and regulations. In view of the above, Linkbest service provider (or "we") has established this Privacy Policy (hereinafter referred to as the "Policy" / "Privacy Policy"). This Policy relates to your use of the Linkbest Services and the various business functions included in the Services (hereinafter collectively referred to as "our products and/or services"), and it is important for you to read and thoroughly understand this Policy before using our products and/or services, in particular, you should emphasize on the terms underlined in bold/bold, and confirm that you fully understand and agree to use the relevant products or services after you have done so. . Once you start using our products and/or services, it means that you have fully understood and agreed to this Policy.
In order to provide you with a better experience with our products and services, we are continually working to improve our technology, and from time to time we may introduce new or optimized features that may require the collection or use of new personal information or a change in the purpose or manner of use of personal information. In this regard, we will separately explain to you the purpose, scope and use of the corresponding information by updating this policy, pop-up windows, page reminders, etc., and provide you with the means to independently choose to agree to the collection and use of the information after obtaining your express consent. If you have any questions, comments or suggestions about the contents of this policy, you can contact us through the contact information in Linkbest.
Part I Privacy Policy
This Privacy Policy section will help you understand the following:
i. how we collect and use your personal information
ii. How we use cookies and similar technologies
iii. How we share, transfer, and publicly disclose your personal information
iv.How we protect your personal information
v. How we store your personal information
vi. How you manage your personal information
vii. How we handle minors' personal information
viii. How to update this privacy policy
ix. How to contact us
I. How we collect and use your personal information
In order to provide you with, and enable you to obtain, better and more personalized products and services, when you use our products and/or services, we will collect and use your personal information based on the following scenarios:
1、Functions necessary to realize the promotion
(i) User registration
We provide you with services based on Linkbest, in order to register as our users and use our services, you need to provide your own ready to use account email and password, we will send SMS verification code to verify whether your email is valid. After your registration, you can continue to improve your real name, ID number, cell phone number and other personal information in your logged-in Linkbest account.
(ii) Showing you information about our products/services
Service log information: When you use the products or services provided by our website or client, we will automatically collect details of your use of our services and save them as relevant web logs. For example, the content of your search query, IP address, browser type, telecommunication operator, language used, date and time of access and records of web pages you visit.
If you have questions or objections about the personalized product or service information (if any) you receive, you may contact us at the contact information listed at the top of this Agreement.
(iii)Help you realize balance withdrawal
When the balance in your account reaches the amount that can be withdrawn, you can realize the balance withdrawal by providing your name, ID number, bank card number, card issuing bank, and card region.
(iv)Features Necessary to Secure Transactions
In order to improve the security of our system when you use our products and/or services, to more accurately prevent phishing scams and to protect account security, we may determine the risk of your account by understanding your browsing information, order information, device information (including MAC address), etc., and may record links that we believe to be risky ("URLs"); we may also collect information about your device to analyze Linkbest system problems, count traffic and troubleshoot possible risks, and send unusual information to us when you choose to do so. "); we may also collect information about your device to analyze Linkbest's system problems, to count traffic and identify possible risks, and to identify when you choose to send us unusual information.
(v)Providing you with other additional services
In order to provide you with more convenient, better quality and personalized products and/or services, and in an effort to enhance your experience, we may collect and use your personal information in the following additional services provided to you. If you do not provide this information, it will not affect your use of the basic services, but you may not be able to get the user experience that these additional services bring to you. You can check the status of the above permissions on an item-by-item basis in your device settings and can turn these permissions on or off at any time at your own discretion.
Please note that by turning on any of these permissions, you authorize us to collect and use the relevant Personal Information to provide you with the corresponding services, and by turning off any of these permissions, you revoke your authorization, and we will no longer collect and use the relevant Personal Information on the basis of the corresponding permissions, and we will not be able to provide you with the services corresponding to such permissions. However, your decision to turn off your authorization will not affect the collection and use of information previously collected based on your authorization.
In order to protect your right to know, we display the following list of operating system permissions that may be applied and used by our products, and you can manage the relevant permissions according to your actual needs.
(vi)Other rules for the collection and use of personal information
1、If the information you provide contains personal information of other users, you need to make sure that you have obtained legal authorization before providing such personal information to us.
2、If we use your personal information for purposes other than those stated in this policy, or use the information collected for specific purposes for other purposes, or if we take the initiative to obtain your personal information from a third party, we will obtain your consent in advance.
If we obtain your information indirectly from a third party, we will explicitly request the third party in writing to collect personal information after obtaining your consent in accordance with the law and inform you of the content of the information shared, and if sensitive information is involved, it should be explicitly confirmed by you before it is provided to us for use, and we will request the third party to make a commitment to the legitimacy and compliance of the source of the personal information, and if the third party violates this policy, we will explicitly request the other party to bear the corresponding responsibility. If the third party violates the law, we will explicitly require the other party to bear the corresponding legal responsibility; at the same time, our professional security team will carry out security reinforcement of personal information (including sensitive information reporting, encrypted storage of sensitive information, access rights control, etc.). We will use no less than the same protection means and measures for our own users' personal information to protect the personal information obtained indirectly.
3、Exceptions to Authorized Consent
You fully understand and agree that we do not need your authorized consent to collect and use your personal information under the following circumstances, and we may not respond to your request for correction/amendment, deletion, cancellation, withdrawal of consent, or request for information:
(1)Related to national security, national defense security;
(2) Related to public safety, public health, and significant public interest;
(3) Related to judicial or administrative law enforcement such as crime investigation, prosecution, trial and judgment execution;
(4) For the purpose of safeguarding your or other individuals' life, property and other significant legitimate rights and interests but it is difficult to obtain my consent;
(5) Personal information that you disclose to the public on your own;
(6) Personal information collected from legitimate publicly disclosed information, such as legitimate news reports, government information disclosure and other channels.
(7) Necessary for the signing and fulfillment of relevant agreements or other written documents with you;
(8) Necessary for maintaining the safe and stable operation of the products and/or services provided, such as detecting and disposing of malfunctions of the products and/or services;
(9) Necessary for legitimate news reporting;
(10) Necessary for academic research institutions to carry out statistical or academic research in the public interest and, when providing the results of academic research or descriptions externally, to de-identify the personal information contained in the results;
(11) Other cases stipulated by laws and regulations.
Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information in such a way that the recipient of the data is unable to re-identify a specific individual and cannot be recovered, or if we may de-identify the information we collect for research, statistical analysis and forecasting purposes, for the purpose of improving the content and layout of the Linkbest platform, for the purpose of providing support for business decisions on products or services, and for the purpose of to improve our products and services, then such processed data will be used without further notice to you and without your consent.
2、How we use cookies and similar technologies
(i)Cookies
In order to ensure that the Website works properly and efficiently, to make your visit easier, and to recommend content that may be of interest to you, we may store information on your computer or mobile device: this information may be a cookie, Flash cookie, or other local storage provided by your browser or associated application (collectively, " Cookies").
Please understand that some of our services are only available through the use of cookies. If your browser or browser-attached service allows it, you may modify your acceptance of cookies or reject our cookies, but rejecting our cookies may, in some cases, interfere with your ability to safely access the Site and use the services we offer.
If your browser or browser add-on service allows it, you may modify your acceptance of cookies or reject our cookies, but if you do so, it may in some cases interfere with your ability to safely visit our website and may require you to change your user settings each time you visit our website.
(ii)Web beacons and pixel tags
In addition to cookies, we use other similar technologies such as web beacons and pixel tags on our websites. For example, the emails we send you may contain a link to an address that links to content on our websites, and if you click on the link, we track the click to help us understand your product or service preferences so that we can proactively improve the customer service experience. A web beacon is typically a transparent image embedded on a website or in an email. Pixel tags in emails allow us to know if an email has been opened. If you do not want your activity to be tracked in this way, you can unsubscribe from our mailing list at any time.
3、How we share, transfer, and publicly disclose your personal information
(i)Sharing
We will not share your personal information with any company, organization or individual outside of Linkbest, except in the following cases:
1. Sharing with explicit consent: We will share your personal information with other parties after obtaining your explicit consent.
Sharing under legal circumstances: We may share your personal information in accordance with the provisions of laws and regulations, the need for litigation dispute resolution, or as required by the administrative or judicial authorities in accordance with the law.
Sharing in case of your active choice: If you purchase goods or services through Linkbest, we will share the necessary information related to the transaction in your order information to the provider of the relevant goods or services according to your choice, in order to realize your transaction and after-sales service needs.
2. Sharing with Affiliated Companies: In order to facilitate the joint provision of services to you based on our affiliated accounts, to recommend information that may be of interest to you, to identify abnormalities in member accounts, or to protect the personal and property safety of Linkbest's affiliated companies or other users or the public from being infringed upon, your personal information may be shared with our affiliated companies. We will only share personal information that is necessary and subject to the purposes stated in this Privacy Policy. If we share your personal sensitive information or our affiliates change the purpose of use and processing of your personal information, we will ask for your authorized consent again.
Please note that due to GDPR, the Order Reference/ID is not made visible on the Awin interface. Please enable us to get access to and view the relevant order reference information if you would like to get the information; if you have any further questions, please contact our support service: admin@linkbest.com
3、Sharing with Authorized Partners：Only to achieve the purposes stated in this Privacy Policy, some of our services will be provided by us and authorized partners. We may share some of your personal information with our partners to provide better customer service and user experience. We will only share your user information for purposes that are lawful, legitimate, necessary, specific, and unambiguous, and will only share user information that is necessary to provide the services. Our partners are not authorized to use the shared user information for any other purpose.
Currently, we have the following types of authorized partners: vendors, service providers, and other partners. We send information to vendors, service providers, and other partners who support our business by providing basic technical services, providing customer service, consulting, analytics, and other professional services.
Companies, organizations and individuals with whom we share user information are subject to strict data privacy agreements requiring them to handle personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.
(ii)Transfer
We will not transfer your personal information to any company, organization or individual, except in the following cases:
1、Obtaining your explicit consent or authorization in advance;
2、Provided in accordance with applicable laws and regulations, requirements of legal procedures, mandatory administrative or judicial requirements necessary;
3、In line with the relevant agreements signed with you (including the electronic agreement signed online and the corresponding platform rules) or other legal documents provided;
4、Involved in mergers, acquisitions, asset transfers or similar transactions, such as involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be subject to this privacy policy, otherwise, we will require the company or organization to re-solicit authorization from you to agree.
(iii)Public disclosure
We will only publicly disclose your personal information under the following circumstances and on the premise of adopting security measures that meet industry standards:
1、According to your needs, the disclosure of your specified personal information under the disclosure method you have explicitly agreed;
2、According to the requirements of laws and regulations, mandatory administrative enforcement or judicial requirements must provide your personal information, we may be based on the type of personal information required and the disclosure of public disclosure of your personal information. Subject to laws and regulations, when we receive such a request for disclosure of information, we may request that legal documents, such as subpoenas or letters of inquiry, must be produced in connection with the request. We strongly believe in being as transparent as possible about the information we are asked to provide, to the extent permitted by law. We carefully scrutinize all requests to ensure that they have a legal basis and are limited to data that law enforcement authorities have a legal right to obtain for specific investigative purposes. Where permitted by law or regulation, the documents we disclose are protected by encryption keys.
(iv)Exceptions to obtaining prior authorized consent for sharing, transferring, or publicly disclosing personal information
In the following cases, sharing, transferring, or publicly disclosing your personal information does not require prior authorized consent:
1、Related to the fulfillment of our obligations under laws and regulations;
2、Related to national security and national defense security;
3、Related to public safety, public health, and significant public interests;
4、Related to crime investigation, prosecution, trial and judgment execution;
5、For the purpose of maintaining your or other individuals' life, property and other significant legitimate rights and interests but it is difficult to get my consent;
6、Personal information that you disclose to the public on your own;
7、Personal information collected from legitimate publicly disclosed information, such as legitimate news reports, government information disclosure and other channels.
According to the law, the sharing and transfer of personal information processed by de-identification and ensuring that the recipient of the data is unable to recover and re-identify the subject of the personal information does not belong to the external sharing, transfer and public disclosure of personal information, and the preservation and processing of such data will not require separate notification to you and your consent.
How we protect your personal information security
(a)We attach great importance to the security of your information. We have taken reasonable and practicable security measures in line with industry standards to protect your information against unauthorized access, public disclosure, use, modification, damage or loss of personal information. For example, data exchanged between your browser and our servers is encrypted by the SSL protocol; we also provide secure browsing on the Linkbest platform using the HTTPS protocol; we use encryption technology to enhance the security of personal information; we use trusted protection mechanisms to prevent malicious attacks on personal information; we deploy access control mechanisms to ensure that only authorized personnel have access to personal information; and we use reasonable and practical industry standard security measures to protect personal information from unauthorized access, public disclosure, use, modification, damage or loss. We deploy access control mechanisms to ensure that only authorized personnel have access to personal information; and we conduct security and privacy training courses to enhance employee awareness of the importance of protecting personal information.
(b)We have an industry-advanced data security management system that focuses on data and revolves around the data lifecycle, and we will enhance the security of the entire system in multiple dimensions, including organizational construction, system design, personnel management, and product technology.
(c) We will take reasonably practicable measures to avoid collecting irrelevant personal information to the best of our ability. We will only retain your personal information for as long as necessary to achieve the purposes stated in this policy, unless an extension of the retention period is required by mutual agreement or permitted by law. We will delete or anonymize your personal information beyond the retention period described above.
(d) In the event that our products and services cease to operate, we will take reasonable measures to protect the security of your personal information, including promptly ceasing activities that continue to collect personal information; notifying users of the cessation of operation by delivery or announcement; and deleting or anonymizing personal information in our possession.
(e) You shall also protect the security of your account. When using Linkbest Platform services, we strongly recommend that you do not send your information using communication methods that are not recommended by Linkbest Platform, and we also ask you to use complex passwords to protect your account security. When using McAlliance Platform products or services, you will inevitably have to disclose your personal information, such as contact information or contact address, to counterparties or potential counterparties. In addition, you may also establish communication, exchange information or analyze content with third parties through our services. Please protect your personal information and provide it to others only when necessary. If you discover that your personal information, in particular your account or password, has been compromised, please contact Linkbest's customer service immediately so that we can take appropriate measures in accordance with your request.
(f) In the unfortunate event of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with the incident, the suggestions you can make to prevent and reduce the risk on your own, and the remedial measures to be taken against you, etc. We will also inform you by email, e-mail or other means of the incident. We will inform you of the situation related to the incident by email, letter, phone call, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to make a public announcement.
At the same time, we will also report the disposition of personal information security incidents in accordance with the requirements of the regulatory authorities.
V. How we store your personal information
(I) Storage location
Personal information collected and generated in our operations in the People's Republic of China will be stored in China. Under the following circumstances, we will provide your personal information to entities outside of China after fulfilling our obligations under the law:
1、Applicable laws have explicit provisions;
2、Explicit authorization is obtained from you;
3. You conduct personal active behavior such as cross-border transactions through the Internet.
In response to the above circumstances, we will ensure, through contracts and other forms, that your personal information is protected to a degree no less than that set forth in this policy.
(ii) Storage period
We will take reasonably practicable measures to endeavor to avoid the collection and processing of irrelevant personal information. We will only retain your personal information for as long as is necessary to fulfill the purposes set out in this policy, unless there is a mandatory retention requirement by law. We determine the duration of storage of personal information by reference to the following criteria, whichever is longer:
1、To fulfill the purpose of transactions related to you and to maintain corresponding transaction and business records in order to respond to your possible inquiries, complaints or lawsuits;
2、To ensure the safety and quality of the services we provide to you;
3、Whether you agree to a longer retention period;
4、 Whether there is any other special agreement on the retention period.
After exceeding the retention period, we will delete your personal information or anonymize it in accordance with the requirements of applicable laws.
VI. How you manage your information You can access and manage your information in the following ways:
(i) Accessing, correcting and supplementing your information
You have the right to inquire, correct or supplement your information. You can inquire, correct or supplement your information by logging into Linkbest mobile client, entering the "Personal Center" page, and clicking on the Settings icon in the upper right corner to inquire, correct or supplement your personal information and personal account information;
If you are unable to access such personal information through the above path, you can contact us through Linkbest online customer service at any time.
(ii) Deletion of your information
You may delete some of your information in the ways listed in "(I) Access, Correction and Supplementation of Your Information". You may request us to delete your personal information in the following cases:
If our handling of personal information violates laws and regulations;
If we collect or use your personal information without your explicit consent;
3、If our behavior of handling personal information seriously violates the agreement with you;
4、If you cancel your Linkbest account; 5. If we terminate our services and operations.
If we decide to respond to your request for deletion, we will also notify the entities that have obtained your personal information from us at the same time, to the extent possible, and ask them to delete it in a timely manner, unless otherwise required by law or regulation, or if these entities have been independently authorized by you. When you delete information from our Services, we may not delete the corresponding information from our backup system immediately, but will delete the information when the backup is updated.
(iii) Changing the scope of your authorized consent
Each business function requires some basic personal information in order to be completed (see "Section 1" of this Privacy Policy). In addition, you can give or withdraw your authorization consent in the settings of your device or our client "Personal Center - Settings - Account Security - System Privileges" or by contacting the Linkbest platform customer service. Please note, however, that we may not be able to respond to your request to change the scope of your authorization for some types of personal information, such as information necessary for the implementation of the basic functions of the products or services of the Linkbest Platform, or information necessary for us to fulfill our obligations under laws and regulations (for details, please refer to (v) Responding to your request above).
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 processing of personal information previously carried out on the basis of your authorization. (iv) Canceling your account
You can log in Linkbest mobile client and apply for canceling your account through "Personal Center - Settings - Account and Security - Cancel Account". After you cancel your account on your own initiative, we will stop providing products or services to you, delete your personal information or anonymize it in accordance with the requirements of applicable laws.
(v) Responding to your request above
For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.
We will respond within 15 days. If you are not satisfied, you may also initiate a complaint through the Linkbest Platform customer service.
In principle, we do not charge you for reasonable requests, but we will charge you a fee for requests that are repeated several times and exceed reasonable limits. We may refuse requests for information that is not directly related to your identity, information that is repeated for no apparent reason, or requests that require excessive technical means (e.g., requiring the development of a new system or a fundamental change in current practices), pose a risk to the legal rights of others, or are impractical.
In the following cases, we will not be able to respond to your request in accordance with laws and regulations:
1、Related to national security and national defense security;
2、Related to public safety, public health, and significant public interest;
3、Related to crime investigation, prosecution, trial and execution of judgment;
4、There is sufficient evidence that the subject of personal information has subjective malice or abuse of rights;
5、Responding to your request will lead to serious damage to your legitimate rights and interests or those of other individuals or organizations;
6、Involving commercial secrets.
7、How we handle personal information of minors
The products and services of Linkbest platform are mainly for adults. Without the consent of parents or guardians, minors are not allowed to create their own user accounts. If you are a minor, we recommend that you ask your parents or guardians to read this Privacy Policy carefully and use our services or provide information to us with the consent of your parents or guardians.
For the collection of personal information of minors through the use of our products or services with the consent of their parents or guardians, we will only use, share, transfer or disclose this information as permitted by laws and regulations, with the explicit consent of their parents or guardians, or as necessary for the protection of minors.
VIII. How to update this privacy policy
(i) In order to provide you with better services and with the development of Linkbest's business, this Privacy Policy will be updated. However, we will not reduce your rights under this Privacy Policy without your express consent. We will issue the updated version on Linkbest's website and Linkbest's mobile terminal and remind you of the update through website announcements or other appropriate means before it takes effect, and we also invite you to visit Linkbest in order to keep abreast of the latest Privacy Policy.
(ii) For material changes, we will also provide a more prominent notice (we will explain the specific changes to the Privacy Policy by means including but not limited to emails, text messages or special notices on the browsing page).
Significant changes referred to in this policy include, but are not limited to:
1. Significant changes in our service model. For example, the purpose of processing personal information, the type of personal information processed, and how personal information is used;
2. A significant change in our control, etc.. Such as changes in information controllers caused by mergers, acquisitions, reorganizations, etc;
3. Changes in the primary recipients of personal information shared, transferred, or publicly disclosed;
4. Significant changes in your right to participate in the handling of personal information and how it is exercised;
5. Changes in the person responsible for the security of personal information or the contact information and complaint channels;
6. personal information security impact assessment report indicates the existence of high risk.
IX. How to contact us
You can contact us through the contact information at the bottom of the website, and we will reply to your request within 15 days: if you have any questions, comments or suggestions about the content of this policy, you can contact us through Linkbest platform online customer service;
If you are not satisfied with our response, in particular if you believe that our personal information processing behavior has harmed your legitimate rights and interests, you can also seek a solution by filing a lawsuit in a court of competent jurisdiction in the defendant's domicile.