Privacy Policy

Last updated: [15^th July, 2021]

We, Alibaba Cloud (Singapore) Private Limited, respect and protect user privacy and will treat the same with great duty of care. When you use the Alibaba Cloud Pin (hereinafter may be referred to as “Digital Pin”) product and the related application (hereinafter may be referred to as “APP”), “Digital Pin” combined with “APP” being referred to as our “Services”, we will collect, process and use your information in accordance with this Privacy Policy.

With this Privacy Policy, we intend to clearly explain how we deal with your personal information. We advise you to read through this Privacy Policy in conjunction with our Alibaba Cloud Pin User Agreement before using our Services.

If you have any questions, comments or suggestions, please contact us via the contact information we provide in Section 9 of this Privacy Policy.

This Privacy Policy includes:

1.       What is Covered by this Privacy Policy

2.       Collection and Use of User Information

3.       Sharing, Transfer and Disclosure of User Information

4.       User Information Retaining, Storing and Management

5.       User Information Security

6.       Protection of Minors

7.       Update of This Privacy Policy

8.       Your Right for your Personal Data

9.       How to Contact Us

1. What is Covered by this Privacy Policy

1.1.    This Privacy Policy shall apply to your registration, use and otherwise interact with our Services, including the control and management of the Digital Pin as well as the related APP.

1.2 This Privacy Policy applies to “Users” (or “you”) of our Services. “Users” includes Digital Pin holders as well as APP users, etc.

1.3   This Privacy Policy shall not apply to services provided by third parties to you. Please refer to the relevant third parties’ privacy policies for information they collect from your use of their products or services. 

2. Collection and Use of User Information

2.1.  Account registration information

To enable you to open an account with the APP, we will collect your email address.

2.2. Information we collect in order to provide you with our Services

To enable us to provide you with the Services, we will collect your personal information, including your first name, last name and your social network accounts (Twitter, Instagram, Facebook). Information on your social network accounts is optional. If you do not provide this information, you will not be able to share your use experience of the Digital Pin on your social networks but can still use the rest of the functions of our Services.

2.3 Information we collect during your use of our services

When you use the APP, we collect information that helps us to deliver the Services and to improve your experience. The information we may collect are:

·         Device information which installs the APP: we will receive and record the information relating to the device you use in accordance with the authority you grant in the installation and use of the APP (such as Bluetooth status, network status, language of the system, time of the device, device resolution);

·         Walking steps;

·         Friends number you have made;

·         Unlocked Pin artworks and the Pin artworks in Use.

We do not track or collect any sensitive information (race, religion, ethnicity or political opinion) about you.

The Digital Pin will be used in combination with the APP installed on the mobile phone or other terminal device. Data collected by the Digital Pin will be synchronised with APP through Bluetooth and vice versa. All data thus collected is referred to as “User Information”.

2.4.    You agree that we use the User Information for the following purposes:

2.4.1. To provide you with, maintain and improve our Services;

·         To manage your access to the APP, and to communicate with you via email as necessary, for example we may email you regarding material changes to this Privacy Policy.

·         To show in the Digital Pin and APP your first and last name, your social network accounts information, walking steps, friends number and profile picture.

·         To manage customer service queries and complaints.

·         To manage your privacy preferences.

·         To send you administrative messages about your account, reminders for upcoming events, service changes, or new policies. These updates, changes and notifications are essential for the Services.

·         To run competitions, prize draws and promotions or for commercial and advertising purpose. In these cases, subject to any specific terms to be agreed with you separately, you grant a global right to Alibaba Cloud to use your name, number of friends you made by using the Digital Pin, number of the unlocked profile pictures, walking steps, social network accounts information for advertising, publicity and promotional purposes in all media now known or discovered afterwards and on the internet.

·         To measure user response and engagement with the Digital Pin and the APP. This may include sharing your information with third parties who help us to make the analysis, assessment and/or to carry out any promotional or marketing events as mentioned above.

·         To help us improve the user experience and to support new product development. We may send you customer satisfaction surveys and market research questionnaires (for which we may share your information with third-party suppliers employed by us).

·         For any purpose required by law or regulation and to verify information that we provide to third parties for compliance and audit purposes.

·         For any other purpose as permitted by you.

·         For other necessary purposes for providing, maintaining and improving our Services to you.

2.4.2 You have the right to object to any of the above uses of your User Information. Please contact us if you wish to do so. We will consider all objections reasonably, but there may be legal reasons where we deem that the use of your User Information is still appropriate. We will explain our decision to you within a legal permitted timeframe.

3. Sharing, Transfer and Disclosure of User Information

3.1 Sharing

We will not share your User Information with any other organization or individual, except in the following circumstances:

·         Sharing with express consent: We will share your User Information with other parties with your express consent;

·         Sharing as required by laws: We may share your User Information as required by laws, regulations, litigation or arbitration, or by administrative or judicial authority in accordance with laws;

·         Sharing with authorized partners:  We may engage our trusted partners (supplier, agent, subcontractor, etc.) to provide services (including underlying technical services, consultation, analysis and other professional and/or marketing services). You agree that we might share your User Information with such partners in order to provide better customer service and optimize user experience. We will only share your User Information for the purposes specified under section 2.4 of this Privacy Policy. Our partners have no right to use the shared User Information for any other purpose. We will obtain your separate consent if required by law;

3.2. International Transfer

Your User Information will be stored in Singapore and may be accessed by staff located in the People’s Republic of China in order to provide the Services. We take appropriate measures to ensure your User Information remain protected in accordance with this Privacy Policy and applicable data protection laws.

3.3  Exceptions to obtaining prior authorization and consent for sharing, transfer and disclosure of User Information

Your User Information may be shared, transferred or disclosed without your prior authorization and consent under any of the following circumstances:

·         Where it relates to national security and national defense security;

·         Where it relates to public security, public health or major public interests;

·         Where it relates to criminal investigation, prosecution, judgment and enforcement etc.;

·         For the purpose of protecting your or other individual’s life, property and other major lawful rights and interests, where it is hard to obtain your prior consent;

·         The User Information is disclosed voluntarily by you to the public;

·         The User Information is collected from the information disclosed through lawful public channels, such as lawful news reports or information disclosure by government etc.; or

·         Any other circumstances allowed under applicable laws and regulations.

4. User Information Retention and Management

4.1. Retention policy

We securely store your User Information, and hold it for and only for a period of one year after the closing ceremony of the Tokyo 2020 Olympic Games (8^th, August of 2021), unless we are required to retain your information for a longer period to comply with applicable legal, tax or accounting requirements.

When the aforementioned retention period expires, we will either delete or anonymize your User Information or, if this is not possible, then we will securely store your User Information and isolate it from any further processing until deletion or anonymization is possible. 

4.2. You may change the User Information on the setting page of the APP.

5. User Information Security

5.1.    We attach great importance to the security of your User Information. We endeavour to take all necessary technical and organisational measures to protect your User Information from unauthorized access, disclosure, use, manipulation, damage or loss.

5.2. We will take reasonable and practical measures to avoid collecting irrelevant and unnecessary User Information to the maximum extent possible. We will retain your User Information only for the period as is necessary to achieve the purposes set forth in this Privacy Policy, unless it is agreed by you and us to prolong the retention period or permitted by law. Upon the expiration of such retention period, we will delete or anonymize your User Information.

5.3.   Upon becoming aware of a data breach, we will notify you and the regulatory authorities in accordance with the timescales and scope required by applicable data protection laws. We may if required by applicable laws and regulations, notify you of the following matters: basic information and possible influence of such security incident, handling measures we have taken or will take, suggestions on how you may prevent or reduce risks on your own, and remedies to be taken for you. If permitted, we will notify you of the relevant information of such incident through email. If allowed by the organisers of the Tokyo 2020 Games, we will publish announcement in a reasonable and effective manner.

5.4.    If we intend to use your User Information for any purpose other than those specified when we collect the same or beyond the scope that is directly or reasonably relevant, we will inform of you the same again and obtain your express consent if required by applicable data protection laws.

6. Protection of Minors

We attach importance to the protection of minors’ privacy. We do not intend to process personal information from individuals under the age of 20. If a user under the age of 20 has provided us with User Information without parental or guardian consent, the parent or guardian should contact via AlibabaCloudPin@service.aliyun.com to remove the information. We will make every effort to delete any details of such users where a parent or guardian has informed us that these details have been collected.

7. Update of this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make and as required by applicable laws, such as by posting an amended Privacy Policy through the APP or communicate such changes to you by email.

You can check this Privacy Policy in the “Privacy and Data Protection” interface of our APP.

8. Your right for your Personal Data

You have the right to inquire, copy, correct, delete, refuse to use, limit the use your User Information we collected during the service process and other rights that apply to you under applicable laws. If you want to exercise these rights, you could send an email toAlibabaCloudPin@service.aliyun.com. We will respond to your requests of exercising your data subject rights in accordance with the required time period and other requirements under applicable data protection laws.

Please note that when you choose to delete the User Information, only your email information will be kept and all other data (including your name, social network accounts, as well as your usage data) will be completely removed. When you subsequently use the Digital Pin and APP at a later date, we will not be able to retrieve any data which has been previously removed.

9. How to Contact Us

If you have any questions or comments on the contents of this Privacy Policy or the practice of this Privacy Policy, you may contact us via AlibabaCloudPin@service.aliyun.com.