Release date: July 1, 2019

Effective date: July 1, 2019

Dear users, you are welcome to browse, register, log in, use (hereinafter collectively referred to as "use") Sugon's website services. We value your privacy and understand the importance of personal information to you. We will collect, store, use, share, disclose and protect your personal information in accordance with the “Sugon Privacy Policy” (hereinafter referred to as “the Privacy Policy”), so please carefully read, understand and agree all terms of this Privacy Policy before using Sugon Service.

This Privacy Policy (hereinafter referred to as “this Policy”) applies to Internet-related services provided by [Dawn Information Industry Co., Ltd.] (hereinafter referred to as “we” or “Sugon”).

I.            This policy will let you know the following:

(1) How we collect and   use your personal information

(2) How do we share,   transfer, and publicly disclose your personal information

(3) How do we store   your personal information

(4) How we protect   your personal information

(5) How do we use   cookies and similar technologies

(6) Account cancel   method

(7) Respond to your claim

(8) How do we protect the personal information of minors

(9) How this Privacy Policy will update

(10) How to contact us

This policy does not apply to other software, products or services provided to you by 3^rd parties.

II.            Reading tips

(1)       By reading this Privacy Policy, you will learn:

Who are we, how to contact us, what business functions are available in Sugon; the types and purposes of your personal information that we collect during the use of Sugon Service, the consequences of your refusal to provide personal information; what is the cookie; Where and how long your personal information is stored; how do we share, disclose, and transfer your personal information; what measures have been taken to protect the security of your personal information; how do you query, correct, delete personal information, change the scope of your consent, and cancel Account; how to make a complaint or submit a proposal; how this Privacy Policy will update.

(2)       When reading this Privacy Policy, please pay special attention to:

1.         Contents use bold and italic, it represents your personal sensitive information.

1.         Contents use bold, it indicates that requires your special attention or focus.

III.            introduction

“We” in this Privacy Policy refers to the operator of the Sugon website service. The basic information is as follows:

1.         Company Name: Dawning Information Industry Co., Ltd.;

2.         Address: Building 36, No.8 Dongbeiwang West Road, Haidian District, Beijing

3.         The function that Sugon provides to you.

IV.            How we collect and use your personal information

Personal information refers to various information recorded electronically or otherwise that can identify a specific natural person or reflect the activity of a particular natural person, either alone or in combination with other information. We collect and use your personal information only for the purposes set out in this policy:

(1)     Situation in which need to collect and use your personal information in order to provide you with core product features

To achieve the core business functions of this product, we may need to collect personal information from you. The core business functions of this product and the personal information collected to achieve this function are listed below. If you refuse to be collected, you will not be able to use this product. 

(2)     Situation of providing you with additional product features that need to collect and use your personal information.

In order to provide you with better products and services, we may need to collect the following information. If you refuse to provide the following information, it will not affect your normal use of the core business functions of the product described in item (1), but we are unable to provide you with certain features and services.

(3)     Exceptions of no need to get your authorization of collect and use your personal information

You fully understand that, in accordance with the provisions of relevant laws and regulations, we do not need your authorization to collect and use personal information in the following circumstances:

1.         Directly related to national security or national defense security;

2.         Directly related to public security, public health or major public interests;

3.         Directly related to criminal investigation, prosecution, trial and execution of judgment;

4.         For the purpose of safeguarding your life, property or other significant legitimate rights and interests, but it is difficult to obtain consent from the person;

5.         The personal information you collect is disclosed to the public by yourself;

6.         Collect your personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels;

7.         The necessary to sign and perform the contract according to your requirements;

8.         Necessary for maintaining the safe and stable operation of the product and related services, such as finding and dealing with faults of the product or service;

9.         Other circumstances stipulated by laws and regulations.

(4)       Rules for the use of personal information

1. We will use the collected personal information in accordance with the provisions of this policy.

2. The personal information you provide or agree to be collected by us in accordance with this policy will be used by us for the duration of your use of this product. When you log out and notify us, we will stop using and delete your personal information or anonymize it.

3. To improve our products, in order to provide you with personalized needs more accord with your service, we will based on your browsing history, equipment information, etc., to extract your preferences, habits, such as characteristics, based on the characteristics of the tags for indirectly portrait to provide more accurate and personalized services and content, and show, push information and possible business advertising. If you do not want to receive the commercial advertisement we send to you, you can reply to unsubscribe via SMS prompt or use other ways provided by us to unsubscribe.

4. We will seek your prior consent when we use your personal information for other purposes not specified in this policy or when we use the information collected for specific purposes for other purposes.

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

(1)     Shared

We will not share your personal information with any company, organization or individual except for the following:

1.         Sharing with your express prior consent or authorization;

2.         Sharing in accordance with applicable laws and regulations, requirements of legal procedures, mandatory requirements of government departments or judicial decisions;

3.         Within the scope required or permitted by laws and regulations, in order to protect the interests, property or safety of Sugon, you and other users or the public from damage, it is necessary to provide;

4.         Only by sharing your information can we realize the functions of our products or provide you with the services you need;

5.         Sharing with our affiliates: your personal information may be Shared among our affiliates. We will only share necessary personal information and such sharing is subject to the stated purposes of this policy. If our affiliates want to change the purpose of processing personal information, they will ask for your authorization again.

6.         Sharing with authorized partners: some of our services will be provided by authorized partners only for the purposes stated in this policy. We may share some of your personal information with our partners to ensure the smooth completion of the services provided for you. We will only share your personal information for legal, legitimate, necessary, specific and specific purposes and will only share such personal information as is necessary to provide services. At the same time, we will sign a strict confidentiality agreement with our partners, requiring them to handle your personal information in accordance with this policy and any other relevant confidentiality and security measures. Our partners have no right to use the shared personal information for any other purpose.

Currently, our authorized partners include the following types:

Suppliers, service providers and other partners. We share the information to suppliers that support the function of our products, service providers and other partners, the support including providing technical infrastructure services, data processing, to carry out marketing activities, service quality monitoring, analyzing using method of our services, to measure the effectiveness of advertisement and services, to provide customer service, payment convenience or academic research and investigation.

Authorized partners of advertising and analysis services. We will not share your personally identifiable information (i.e. information that can identify you, such as your name or email address, through which you can be contacted or identified) with partners providing advertising and analysis services unless we obtain your permission. We provide these partners with information about the reach and effectiveness of their advertising without providing personally identifiable information about you, or we aggregate this information so that it does not identify you personally.

(2)     The transfer

We will not transfer your personal information to any company, organization or individual, except for the following:

1.         Obtain your express prior consent or authorization;

2.         Transfers are made in accordance with applicable laws and regulations, requirements of legal procedures, mandatory requirements of competent government departments or as required by judicial decisions;

3.         In the case of merger, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be subject to this policy. Otherwise, we will require the company or organization to seek authorization from you again.

(3)     Public disclosure

We will only publicly disclose your personal information in the following:

1.         Obtain your express prior consent or authorization;

2.         We may publicly disclose your personal information according to the type and manner of disclosure required by applicable laws, regulations, legal procedures, mandatory requirements of competent government departments or judicial decisions. In the event of any of the above situations, we will require the disclosing party to provide the relevant effective legal documents and take security measures in accordance with legal and industry standards for the disclosed information.

(4)     Exception regarding getting prior authorization when sharing, transferring or publicly disclosing personal information

We will seek your prior consent when using your personal information for other purposes not specified in this privacy policy. When we want to use the personal information collected for a specific purpose for other purposes, we will ask for your prior consent.   Please be fully aware that in the following we do not need to ask your authorization:

1.         Related to national security or national defense security;

2.         Related to public security, public health or major public interests;

3.         Related to criminal investigation, prosecution, trial and execution of judgment;

4.         For safeguarding your life, property or other significant legitimate rights and interests, but it is difficult to obtain your consent;

5.         The information collected is disclosed to the public by you;

6.         Collecting information from legally disclosed information, such as legitimate news reports, government information disclosure and other channels;

7.         It is necessary to sign and perform the contract according to your requirements;

8.         Necessary to maintain the safe and stable operation of our services, such as the discovery and disposal of faults of products or services;

9.         Necessary for legitimate news reporting;

10.      When it is necessary for an academic research institution to carry out statistics or academic research based on public interests and to provide the results of academic research or description to the outside world, the information contained in the results shall be de-identified;

11.      Other circumstances stipulated by laws and regulations.

Please understand and agree that, if your information (such as search keyword information) cannot be independently or in combination with other information to identify your personal identity, it does not belong to your personal information in the legal sense; Your personal information will be treated and protected in accordance with this privacy policy during the combined use period only when your information can be identified to your personal identity by itself or in combination with other information.

In accordance with the law, if we take technical measures and other necessary measures to de-identify personal information, and ensure that the recipient cannot recover and re-identify the subject of personal information, the sharing, transfer and public disclosure of such data will not need to inform you and obtain your consent.

VI.            How do we store your personal information

1.         Storage location

In accordance with the requirements of laws and regulations, we will collect and produce personal information within the territory of the People's Republic of China and store it within the territory of the People's Republic of China.

2.         Storage time

We will only retain your information during the term of your account or for as long as necessary to provide you with product-related services and technical support. We will also retain your personal information for as long as necessary to comply with applicable legal obligations, resolve disputes and enforce the agreement.

(1)       Shelf life

We consider the following three factors to determine the retention period of your personal information:

①　Minimum storage period stipulated by law, such as the minimum storage time stipulated by network security law and e-commerce law.

②　In order to provide the necessary period of time for the purpose of providing Sugon official website/service, such as when you use the corresponding function of Sugon official website after you register/login with your mobile phone number, we will keep your mobile phone number during the period when you provide and use the function, so as to provide you with the function normally.

③　For example, according to article 13 of the regulations on protection of information network communication, we need to provide the name (name), contact information and other information of the service objects suspected of infringement to relevant administrative departments.

We will delete or anonymize your personal information after it has expired.

For personal information beyond the deadline, we will immediately delete or do anonymous processing.

VII.            How do we protect your personal information

We have used industry-standard security measures to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable measures to protect your personal information. For example, when transferring sensitive information, we use encryption to protect the security of your information; We will use trusted protection against malicious attacks on our data; We will deploy access control mechanisms to ensure that only authorized personnel have access to personal information. In addition, we will conduct security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

We will take all reasonably practicable measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for as long as is necessary to achieve the purposes stated in the cost policy, unless the retention period is extended or permitted by law.

The Internet is not an absolutely secure environment. No product, service or data transmission can guarantee 100% security. In the event of an unfortunate personal information security incident, we will, in accordance with the requirements of laws and regulations, timely inform you of the basic situation and possible impact of the security incident, we have taken or will take the disposal measures, you can independently prevent and reduce the risk of suggestions, your remedial measures, etc. We will timely inform you of the relevant information by email, letter, phone call, push notification and other means; When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to release the announcement. At the same time, we will also comply with the requirements of the regulatory authorities, take the initiative to report the handling of personal information security incidents.

VIII.            How do we use cookies and the like

When you use our products/services, we will use cookies and similar technologies to automatically collect your information and store it as log information. You can clear cookies saved on your computer, or enable Do Not Track, a feature found in most web browsers. See About Cookies.org for details. However, please note that if you clear the cookie saved by your computer or enable the do not track function, this will cause us to be unable to provide you with a complete product/service. Collection and use purposes are shown in the following table:

Various purposes of cookies      A detailed description

The authentication cookie informs us when you log in to our products/services so that we can provide the right service and experience for you.

Scenario example: when you log in the official website of Sugon, the cookie will inform us, let us identify whether you have logged in the product/service safely, and display the information related to you only.

We use cookies to protect your personal information and the security of our services and to prevent fraud, criminal or other suspected criminal ACTS.

Example scenario: cookies can identify whether you are logging into our services at our normal location, prevent your data from being stolen, and identify theft.

Service optimization: we use cookies to perform our service functions and enhance them.

Example scenario: cookies can help us to fill in your account data in advance and facilitate your use of our services.

Cookies can record your use of our products/services to ensure that you are presented and pushed with content that interests you more.

Improve efficiency: we use these cookies to improve the speed, performance, and efficiency of our services.

Example scenario: these cookies facilitate the flow of router information between servers and verify the speed at which different users use our services: we may also use cookies to temporarily store data locally on your client side to speed up the speed at which you use our services.

Analysis and research: we use cookies to follow up our service performance and improve service level. Cookies also provide us with reference data to develop new functions.

Example scenario: cookies give us a deeper understanding of how to use our services and therefore help us enhance the experience for you and other users. Such data includes the time spent on each program when you log on to our services, what programs you use when you use our services, and which web pages and functions you used when you used our services.

IX.            The path to log out

(1)     You can choose the following ways to apply for the cancellation of the Sugon network account, once you cancel the Sugon network account, you will not be able to use the Sugon network service, so please be careful operation:

(2)     Call Sugon customer service number: Customer service will verify your identity and relevant information, after verification, in the background to cancel your account.

X.            Respond to your rights request

Please understand and agree that we do not charge for your reasonable requests in principle, but we will charge a certain cost for repeated requests beyond the reasonable limit as the case may be. We may reject requests that require too much technology, cost too much money, or have other significant difficulties (for example, the need to develop new systems or fundamentally change existing practices), or that put the legitimate rights and interests of others at risk.

After verifying your identity, we will reply or make an explanation to you within 15 days or within the time limit stipulated by laws and regulations, whether or not your request will be fulfilled.

Please be fully aware that you may not get response of your request for inquiry, deletion, correction, authorization withdrawal or account cancellation in the following circumstances:

1.         Directly related to national security or national defense security;

2.         Directly related to public security, public health or major public interests;

3.         Directly related to criminal investigation, prosecution, trial and execution of judgments;

4.         We have sufficient evidence that you have subjective malice or abuse of rights;

5.         Responding to your request will cause serious damage to your or other individuals' or organizations' legitimate rights and interests;

6.         Involving trade secrets.

XI.            Stop running

If we cease operation, we will stop the activity of collecting your personal information in time, notify you of the cease operation in the form of announcement, and delete or anonymize your personal information.

XII.            How do we protect the personal information of minors

We attach great importance to the protection of minors' personal information.   In accordance with relevant laws and regulations, if you are a minor under the age of 18, please ask your parents or guardian to read this privacy policy before using our services, and obtain the consent and guidance of your guardian before submitting your personal information.

XIII.            How is the privacy policy updated

(1)     We may amend the terms of this privacy policy.

We will post the changes to this privacy policy on this page. For major changes, we will notice you prominently on the homepage or otherwise notify you. If you do not agree with the updated version, please stop using the services provided by Sugon. If you continue to use our products/services, you agree to be bound by the revised privacy policy.

(2)     "Major change" means one of the following:

1.         Our core business model has changed significantly.

2.         We have made major changes in ownership structure, organizational structure and so on. Such as business adjustment, bankruptcy mergers and acquisitions caused by the owner change.

3.         The main objects of personal information sharing, transfer or public disclosure have changed.

4.         Your right to participate in the processing of personal information and the way it is exercised has changed significantly.

5.         We are responsible for handling complaints, suggestions and changes in the contact information of this privacy policy.

XIV.            How to contact us

If you have any questions about this privacy policy or issues related to this privacy policy, or have any complaints or suggestions about our services, please contact us by:

Email: support@sugon.com

Feedback: 400-810-0466

Normally, we will reply within 15 days. If you think our personal information processing behavior damages your legitimate rights and interests, you can also go to the network information department, industry and information department, public security and industrial and commercial regulatory departments for complaints or reports.