BestCEM Privacy Policy

Released on March 19, 2020

Effective on March 19, 2020

Important Note:

Shanghai Zhongyan Network Technology Co., Ltd. (hereinafter referred to as “Zhongyan” or “We”) attaches great importance to the protection of users’ personal information. We may collect and use your relevant information when you download, open, browse, register, login and use the products and/or services related to Zhongyan’s website (www.bestcem.com). This BestCEM Privacy Policy (the “Privacy Policy”) is intended to explain to you how we will collect, use, store and share such information, and the methods which we have made available to you to access, update, control and protect the same.

We have tried to keep the relevant technical terms used herein as plain and as concise as possible to facilitate your understanding. The terms of this Privacy Policy which are or may be closely related to your rights and/or interests have been highlighted in bold for your special attention.

This Privacy Policy contains the following:

1. Introduction

2. Why we collect your information

3. How we collect your personal information

4. How we store your personal information

5. How we use Cookies and similar technologies

6. How we use your personal information

7. How you can access and manage your personal information

8. Information security

9. Emails and messages we may send to you

10. Amendment to the Privacy Policy

11. Contact, complaints and reporting

12. Operator of the product and/or service

13. Governing Law and Dispute Resolution

1. Introduction

Before your use of any of our products or services, please carefully read and fully understand this Privacy Policy, and make appropriate choice after confirming your full understanding hereof. By ticking the box of “I accept BestCEM Privacy Policy” (or other button indicating your acceptance of this Privacy Policy), you accept that we may collect, use, store and share your relevant information in accordance with this Privacy Policy. If you use or continue to use our products or services and complete the questionnaire after we have updated this Privacy Policy, you will be deemed to have accepted this Privacy Policy and its updates and agreed to our processing of your personal information in accordance with this Privacy Policy. If you do not accept this Privacy Policy, please do not use or immediately stop using our products and/or services.

By using or logging in/registering your account for the first time, you agree to this Privacy Policy. However, this does not mean that we will immediately collect all the personal information contained in this Privacy Policy. We will only collect and use the corresponding personal information in accordance with this Privacy Policy when you activate or use certain function by browsing, voluntary fill-in, clicking or other voluntary actions.

2.Why We Collect Your Information

By visiting the “Get Free Account” webpage on bestcem.com and submitting your information as requested, you are indicating that you are interested in and actively pursue a possible cooperation with us.

In order to fully understand your product requirement and for the purpose of providing you with the trial products and services, we need to collect the following information from you: name, mobile phone number, email address, company name and industry. Such information is necessary for us to contact you and provide you with an access to trials of BestCEM’s products in accordance with the principle of data minimization. You will, on an ongoing basis, authorize us to use the information so provided by you during your trial of our products and services. Upon your request for deregistration of the information, we will stop using or delete such information, or anonymize your personal information, unless otherwise provided by laws or regulations.

3. How We Collect Your Information

By submitting information through the “Welcome to BestCEM Product Trial” page on bestcem.com, you agree that we may receive, use, summarize, analyze, store and transmit such personal information authorized and provided by you as may be required for the communication of your actual needs for product trials, the trial services and possible subsequent product cooperation. Through use of the collected information, we will be able to provide you with trial products or irregular updates to our products. For the purpose of providing you with a better experience and improving our services, or for other purposes which you may consent to, we may, subject to the applicable laws and regulations, use the information collected through certain services for our other services. We will collect your personal information in a lawful, reasonable and minimal manner. BestCEM will collect and use your personal information for the following purposes:

3.1 Registration and Login

If you use BestCEM for one-stop customer experience management, you will need to register/login (login means you are registered as a user of BestCEM), and we will collect the following personal information depending on how you register/login:

3.1.1 Mobile phone number, which is the personal information you voluntarily provide to us when you choose to register/login with your mobile phone number. Also, we will verify the validity of your account by sending you an SMS verification code;

3.1.2 Name, which will, for the purpose of offering better service to you, only be used if necessary to contact you;

3.1.3 Email address, which is the personal information you voluntarily offer to us when you choose to register/login with your email address. Also, we will verify the validity of your account by sending you an email;

3.1.4 Company name and industry, which are collected for the purpose of providing a better service in conjunction with industry solutions.

3.2 Payment Information

If you choose to make payment via bank card, Alipay or WeChat when purchasing BestCEM’s products and/or services, you will be required to provide us with information about your bank card, or Alipay / WeChat account at the time of selecting your specific payment method, so as to proceed with your purchase of the intended products/services. In the process of your payment, BestCEM will not provide a third party with any private information regarding your personal credit card or bank card. In the event that you are redirected to a third-party payment page directly at the time of making a payment, such third party will collect your payment information directly, and the collection, use, storage and sharing of such information will be subject to the privacy policy of such third party and have nothing to do with BestCEM, so please make sure you have carefully checked such third-party privacy policy in advance.

3.3 Security Protection

For the purpose of improving the safety of your use of BestCEM’s services, protecting your or other people’s personal and property safety from any harm or damage, better preventing security risks that may arise out of any phishing site, fraud, network vulnerability, computer virus, network attack, network intrusion or illegal content, and for more accurately identifying a violation of laws and regulations or a breach of the relevant protocol rules established by us, we may use or integrate the information regarding your account, transactions, devices, locations and logs as well as the information which you may authorize to, or be required by laws to share with, our affiliates or third-party partners, so as to comprehensively assess the risk to which your account and transactions may be exposed to, to detect and prevent security incidents, and to take the necessary measures to conduct record-keeping, auditing, analysis and disposal in accordance with the law.

3.3.1 Logs mean the technical information that may be automatically collected by our systems through Cookies, web beacons or other means when you use our products and/or services, including:

(1) device or software information, such as the configuration, version and device identification code of your mobile device and information about your device location that may be provided by your mobile device, web browser or other program for accessing our products and/or services (e.g. the brand, model, software version, identification code and identifier of your device, your IP address, GPS location and network usage habits, and WLAN access point, Bluetooth, base station and other sensor information which can provide relevant information), etc.;

(2) the information you have searched or browsed while using our products and/or services, such as the search terms you have used, your browser type, the URL addresses of those social media pages you have visited, the date and time of your visits, system error logs, and records of your visited webpages, as well as details of other information and contents you have browsed or requested in using our products and/or services;

(3) the information about the communications you have made through our products and/or services, such as the account from which you have communicated, as well as the time, data and duration of the communication;

(4) the information (metadata) contained in contents shared through our products and/or services, such as the date, time or location of those photos, audios or video recordings which you have taken or uploaded.

(5) We may obtain the information generated or shared in your use of a third-party partner. For example, when you use your QQ or WeChat account to log into the service of a third-party partner, we will obtain the name of the third-party service and your log-in time to enable you to manage your authorization. Please carefully read through the service agreement and privacy policy of the third-party service provider.

3.3.2 Location Information includes the information, which you or other users provide to us in the use of BestCEM’s products and/or services and which contains your geographical location.

Our system may collect the information in your use of our products and/or services in order to provide you with a complete product and/or exclusive services. For example, in order to provide you with a survey and research that is more tailored to you, we may collect and link the personal information about the services you use and how you use them.

3.4 Exceptions

In accordance with the relevant laws and regulations, we may collect and use your personal information without your authorization and consent if:

3.4.1 it is in relation to national security or national defense security;

3.4.2 it is in relation to public security, public health, or major public interests;

3.4.3 it is in relation to criminal investigations, prosecutions, trials, or execution of judgements, etc.;

3.4.4 the purpose is to protect your or other individuals’ life, property or other material legitimate rights and interests but it is difficult to obtain your consent;

3.4.5 the personal information so collected has been made public by yourself at your own discretion;

3.4.6 the personal information is collected from lawful public disclosures, such as lawful news reports, disclosures of government information, new media platforms, and other sources;

3.4.7 it is necessary for entering into a contract according to your request;

3.4.8 it is necessary for maintaining the security and stability of the product or service provided, such as for detecting and handling faults in the product or service;

3.4.9 it is necessary for legitimate news reporting;

3.4.10 the information is necessary for an academic research organization to carry out statistical or academic research for public interests, and the personal information contained in the results of the academic research has been de-identified when the results of the academic research or description are made available to the public; or

3.4.11 there is other circumstance as provided for by laws and regulations.

Please understand and agree that, if your information cannot identify you either alone or in combination with other information, the information is not your personal information for legal purposes; and your information will be treated and protected as your personal information in accordance with this Privacy Policy (for the duration of its combined use if used in combination with other information) only when it can identify you alone or in combination with other information.

4. How We Store Your Personal Information

4.1 During your trial of products and services through bestcem.com, we will continue to store your personal information for you. In principle, the personal information we collect and generate in our operation within the People’s Republic of China will be stored in the People’s Republic of China, except for the following circumstances:

4.1.1 where there are express provisions in laws and regulations;

4.1.2 where your express authorization is obtained.

In respect of the above circumstances, we will ensure that protection is provided for the security of your personal information in accordance with laws, regulations and this Privacy Policy.

4.2 We comprehensively consider the following elements in determining the period for storing your personal information:

4.2.1 the shortest retention period required by laws, such as the shortest period under the Cybersecurity Law, the E-commerce Law, etc.;

4.2.2 the period necessary for the provision of our products / services; for example, when you use the corresponding function after registration / login with your mobile phone number, we will continually store your mobile phone number as long as you provide and use the function, so as to provide the same to you properly;

4.2.3 the retention period for the purpose of performing other statutory obligations; for example, in accordance with Article 13 of the Regulations on the Protection of the Right to Information Network Communication, we are required to provide the copyright administrative authority with the name, contact details and other information of the recipient of our service who is suspected of infringement; and

4.2.4 the relevant web logs for monitoring and recording network operation status and network security incidents shall be kept for at least six months.

4.3 After the retention period of individual users’ information expires, we will delete or anonymize users’ personal information by way of formatting or other means in accordance with the relevant laws and regulations as well as our policies.

4.4 If you do not request the deletion of the above information, we will store your information in accordance with the provisions of the Cybersecurity Law of the People’s Republic of China and other laws, regulations and regulatory documents. We will collect, use, store and transmit your information in accordance with the strict security standards and specifications required by laws and regulations, and, through this Privacy Policy, inform you of the purpose and scope of use of the relevant information. We have established a sound system for managing information security and an internal mechanism for handling security incidents. We will adopt reasonably practicable security measures and technological means meeting industry standards to store and protect your personal information from any loss, unauthorized access, public disclosure, use, modification, destruction or leakage. We will take all reasonably practicable measures to protect your personal information. We will use encryption to ensure the confidentiality of data, and we will use reliable protection mechanisms to protect our data from malicious attacks.

5.How We Use Cookies and Similar Technologies

5.1 We, or our third-party partners, may collect and use your information through Cookies and web beacons and store the information as logs.

5.2 We use our own Cookies and similar technologies for providing your with more personalized user experience and products and/or services as well as for the following purposes:

5.2.1 to remember your identity; for example, Cookies help us to recognize your identity as our registered user, or to store your preferences or other information you have provided us; and

5.2.2 to analyze your use of our products and/or services; for example, we may use Cookies to understand what activities you have used our products and/or services for, or which webpages or products and/or services are most popular with you.

5.3 You can block or manage Cookies through your browser settings. However, please note that if you disable Cookies or web beacons, we may not be able to provide you with the best service experience, and some of our products and/or services may be unable to function properly.

5.4 In order to confirm your usage pattern and the use condition of our website, our website will record the IP address of your device, your browser type, and users’ browsing behavior and operations, etc. to help us improve Zhongyan’s design and layout.

6. How We Use Your Personal Information

6.1 We may use the information we collect in the provision of our products and/or services to you for the following purposes:

6.1.1 to provide you with products and/or services, and the personal information we collect and use is a requisite for the provision of our services to you and we will be unable to provide you with some of the relevant service content in the absence thereof;

6.1.2 for the purposes of identity verification, customer service, security protection, fraud monitoring, archive and backup in the provision of our products and/or services to ensure the security of the products and services we provide to you;

6.1.3 to help us to design new products and/or services and to improve our existing products and/or services;

6.1.4 to enable us to have a better understanding of how you access and use our products and/or services, so that we can make tailored responses to your personalized needs, such as language selection, location settings, personalized help services and instructions, or other responses to you; and

6.1.5 for other purposes agreed by you.

6.2 Subject to the relevant laws and regulations, we may use the information we collect through one certain product/service for our other products/services in the form of pooled information or other personalized manner for the purposes of enhancing your experience, improving our products and/or services, or for other purposes agreed by you. For example, the information collected during your use of one of our products or services may be used in another product or service to provide you with specific content or to present to you the non-generally pushed information related to you. If we offer corresponding option in relevant product and/or service, you may also authorize us to use the information collected and stored by such product and/or service for our other products and/or services.

6.3 For the purposes of providing you with improved products and/or services and enhancing your experience, we may analyze and commercially utilize our user database after collecting your personal information. We will, in accordance with the laws and regulations and on the basis of the principles of lawfulness and necessity, take necessary security measures for the relevant information, such as de-identification of the data by technical means.

You understand and agree that, after collection of your personal information, we will de-identify the data by technical means, and that the personal information so de-identified will not be able to identify you, in which case we shall have the right to use the de-identified personal information for the analysis and commercial exploitation of the user database.

7. How You Can Access and Manage Your Personal Information

7.1 Checking Your Personal Information

7.1.1 You may check your personal information by logging into your account at any time, and check your avatar, account name/mobile phone number and name by clicking your avatar & name at the top right corner.

7.1.2 You may check the questionnaires/projects you have created in the “Questionnaire Center/Projects”.

If you cannot access and manage the aforesaid personal information via the above path, you may contact us at any time by use of our contact details set forth in this Privacy Policy, and we will respond to your request for access within 15 days for our receipt of your request.

7.2 Deleting Your Personal Information

7.2.1 You may submit a request to us for the deletion of your personal information in any of the following circumstances:

(1) our processing of the personal information violates laws and regulations;
(2) we collect and use your personal information without your express consent;
(3) our processing of the personal information is in material breach of our agreement with you;
(4) you no longer use our products or services, or you deregister your account on your own initiative; and
(5) if we decide to respond to your request for deletion, we will at the same time notify the persons and entities who have obtained your personal information from us as far as possible and request them to delete the information promptly, unless otherwise stipulated by laws or regulations or such persons or entities have your separate authorization.

When you delete your information from our service, we will not immediately remove the corresponding information from our backup system, but will delete it when the backup is updated.

7.2.2 You may delete any released questionnaire by clicking the “Questionnaire Center/Projects” - “Delete”.

7.3 Deregistration of Account

You may submit your request for account deregistration by sending an email to our customer service at service@idiaoyan.com, and we will process the request after verifying your identity. After account deregistration, we will delete or anonymize the personal information we have collected.

7.4 Response to Your Above Request

7.4.1 For security purpose, you need to submit the request on your own initiative or use other methods to prove your identity. We will request you to verify your identity before processing your request.

7.4.2 We will reply within 15 days upon our receipt of your request. If you are not satisfied, you may also initiate a complaint by using our contact details set out in this Privacy Policy.

7.4.3 In principle, we will not charge fees for the processing of your reasonable requests, however, cost will be charged for repeated and unreasonable requests. We may reject your request that is unnecessarily repeated, needs excessive technical means (for example, the need to develop a new system or fundamentally change current practices), brings risks to the legitimate rights and interests of others, or is highly impractical.

7.4.4 In accordance with the requirements of laws and regulations, we may not be able to respond to your request under any of the following circumstances:

(1) where the request is in relation to national security or national defense security;
(2) where the request is in relation to public security, public health, or major public interest;
(3) where the request is in relation to criminal investigation, prosecution, trial, and execution of judgement, ruling or administrative authority’s decision, etc.;
(4) where there is sufficient evidence that you are intentionally malicious or abuse your rights;
(5) where responding to your request will lead to significant damage to your or any other individual or entity’s legitimate rights and interests; or
(6) where the request involves any trade secret.

7.5 Cessation of Operation

In the event that we cease operations, we will promptly cease the collection of your personal information, notify you of the cessation of operations by way of public announcement, and delete or anonymize your personal information in our possession.

8. Information Security

8.1 We will only retain your personal information for the purposes set forth in this Privacy Policy and for as long as permitted by laws or regulations.

8.2 In order to protect the security of your information, we will, based on the currently available technologies, take reasonably necessary measures to protect your information, including physical, technical and administrative measures to prevent the loss, misuse, unauthorized access, disclosure and alteration of your information. Such protective measures include:

8.2.1 We have established an internal-control system in relation to personal information and only grant minimum necessary authorization to those employees who may have access to your personal information; our employees’ handling of your information is under our systematic monitoring, and trainings on the relevant laws, regulations, and privacy and security-related guidelines as well as promotions for strengthening security awareness are offered to them on an ongoing basis.
8.2.2 We have developed an emergency plan for personal information security incidents and will organize regular trainings and drills on emergency response for relevant internal personnel to enable them to know well about their job responsibilities and the strategies and protocols for handling emergencies. If unfortunately, a personal information security incident occurs, we will, as required by laws and regulations, promptly inform you of: the basic information of the security incident and its possible impact, the measures we have taken or will take to deal with it, the suggestions on how you can prevent and mitigate the risk by yourself, the remedial measures applicable to you, etc. We will inform you of the incident by email, letter, telephone call or push notification, etc. Where it is difficult to inform each personal information subject, we will issue a public announcement in a reasonable and effective way. Meanwhile, we will report the disposition of such personal information security incident in accordance with the requirements of regulatory authorities.
8.2.3 We will adopt security measures consistent with industry standards, including establishing reasonable policies, regulations and security technologies to prevent any unauthorized access to or use and modification of your personal information and to avoid any damage or loss of data.
8.2.4 Our network service adopts data encryption technology at the transmission layer to protect users’ data in the transmission process.
8.2.5 We use encryption technology to store your personal information in an encrypted manner and isolate it through access restriction. In using personal information (e.g. display of personal information and correlation calculation of personal information), we will adopt multiple data desensitization technologies including content replacement and hidden content to enhance the security of personal information in use.
8.2.6 We use strict data access controls and multiple identity verification technologies to protect your personal information from any illegal use.
8.2.7 We only allow relevant employees and partners who have a need to know to access your personal information, and maintain strict access control and monitoring mechanism for this purpose. We also impose corresponding confidentiality obligations on all persons who may have access to your personal information.

8.2.8 Please understand that, even if we have tried to strengthen our security measures as far as possible, we still cannot guarantee that your personal information would be 100% secure at all times due to technical limitations and limitations in risk preventions. Please understand and be aware that, due to various unforeseeable circumstances, the systems and communication networks that you use to access BestCEM’s services may have problems caused by the circumstances beyond our control.
8.2.9 Please understand that the Internet is not an absolutely safe environment, and we strongly advise you not to send your personal information in a way that is not recommended by BestCEM. You may establish contact and share information through our services. When you make communications, transactions or shares through our services, you will may, at your own discretion, choose with whom you intend to communicate, trade or share, as a third party that can see your contact details, communicated information or shared content, etc.
8.2.10 Please properly protect your personal information and provide it to others only when necessary. If you discover that your personal information, especially your account or password, has been leaked, please contact the counterparty immediately, and we will, if necessary, assist in handling such matter immediately upon receipt of your request.

8.3 Please properly keep your BestCEM account and password safe when you use BestCEM’s products and/or services, as we will use your account and password to verify your identity. Any operation or instruction made by use of your account and password will be deemed to have been made by you, and you shall be solely liable for any risks and losses arising from any fraudulent use, theft or illegal use of your account, password or other information attributable to your own reasons. If you are aware that your BestCEM account and password have been or will be leaked for any reason, please contact our customer service immediately so that we may take appropriate measure, but we will not be liable for it until we become aware of the situation and take action within a reasonable time.

9. Emails and Messages We May Send to You

9.1 Email and Push Notification

We may use your information to send email, news or push notifications to your devices when you use our products and/or services. If you do not wish to receive push notification, please send a request to the following email address of BestCEM’s customer service: service@idiaoyan.com.

9.2 Public Announcement Relating to Products and/or Services

We may provide you with announcements relating to products and/or services when necessary (for example, when a service is suspended for system maintenance). You may not be able to cancel such announcements regarding products and/or services.

10. Amendment to the Privacy Policy

In the event of “material amendments” to the Privacy Policy in relation to any of the following major changes, we will notify you by placing a prominent notice on our homepage or otherwise inform you thereof. If you do not accept such amendment, please stop using any related products and/or services of bestcem.com, and, if you continue to use our products and/or services, you will be deemed to have agreed to be bound by the amended Privacy Policy:

10.1 major changes in our core business model;

10.2 major changes in our ownership structure, organizational structure, shareholding structure or other aspects, such as changes in owners as a result of business adjustment, bankruptcy, reorganization, merger and acquisition, spin-off, etc.;

10.3 changes in the main targets with/to whom personal information is shared, transferred or publicly disclosed.

10.4 major changes in your rights to participate in the processing of personal information or the manners in which such rights may be exercised; or

10.5 changes in our contact details for receiving complaints and suggestions regarding personal information and for this Privacy Policy.

If you have any further questions or suggestions, please contact us. We are always committed to fully protecting your information and providing you with better experience and service.

11. Contact, Complaint and Reporting

11.1 If you experience any difficulties in using BestCEM’s products/services, please feel free to contact us. Our contact details are as follows:

11.1.1 Customer Service Email: [service@idiaoyan.com].
11.1.2 Customer Service Hotline: [4006-188-166 ext. 807] (9:30am - 6:30pm, Monday to Friday).

11.2 If, in your use of BestCEM’s products/services, you become aware that your information has been used for illegal acts or infringed, you are welcome to actively report to us, and we will accept and handle it in accordance with the requirements of the Cybersecurity Law of the People’s Republic of China and other laws. In such case, you will be required to provide legal and valid proof of rights, infringement facts, identity certificate and other documents for our verification, and we will reply and inform you of the results within 15 days. You may also file a complaint or report to the cyberspace administrative authority, industry and information technology authority, public security authority, administration for industry and commerce, and other relevant regulatory authorities.

12. Operator of the Product and/or Service

12.1 Operator: Shanghai Zhongyan Network Technology Co., Ltd.

12.2 Registered Address: Units 2003, 2004 & 2005, Building B2, No.700 Yishan Road, Xuhui District, Shanghai

12.3 Tel.: 4006-188-166 ext. 807 (9:30am - 6:30pm, Monday to Friday).

13. Governing Law and Dispute Resolution

This Privacy Policy shall be governed by and construed in accordance with the laws of the People’s Republic of China, and any dispute arising between you and us shall be settled through friendly consultation. If no agreement can be reached through such consultation, either party may submit the dispute to the competent people’s court in the place where Zhongyan is located for settlement through litigation.