Privacy Policy

The purpose of this privacy policy (the “Policy”) is to provide you with information on how Chayora (the Chayora group and its affiliates, hereinafter referred to as “Chayora”, “We”, “Us”) collect and use your Personal Information (as defined below) when you visit our website. Also, it includes information regarding your privacy rights with respect to the processing activities above. We encourage you to read carefully, and make sure you fully understand and agree to the Policy before starting to use the products and services we provide or to take above actions. If you have any questions, please contact us.

This Policy applies to all Chayora products, services and business scenarios that display or refer to the Policy. However, this Policy may not include all possible scenarios of Personal Information processing. Therefore, further to this Policy, you will be provided with the special privacy statement or supplementary notice (“Product Privacy Notice”) issued by Chayora for the particular product, service or business scenario that is being used. The Product Privacy Notice constitutes an important part of this Policy, which contains basic information such as how your Personal Information will be processed under each product, service or business scenario, and how to exercise your privacy rights, etc. We thus recommend that the Product Privacy Notice be read carefully. If there is any discrepancy between the Product Privacy Notice and this Policy, the Product Privacy Notice shall prevail. For the content not mentioned in the Product Privacy Notice, this Policy shall be referred.产品隐私通知”) issued by Chayora for the particular product, service or business scenario that is being used. The Product Privacy Notice constitutes an important part of this Policy, which contains basic information such as how your Personal Information will be processed under each product, service or business scenario, and how to exercise your privacy rights, etc. We thus recommend that the Product Privacy Notice be read carefully. If there is any discrepancy between the Product Privacy Notice and this Policy, the Product Privacy Notice shall prevail. For the content not mentioned in the Product Privacy Notice, this Policy shall be referred.

Chayora highly respect your privacy and is committed to comply with the laws and regulations including the personal information protection law and data security law to protect your Personal Information. According to the applicable laws and regulations, Chayora will be the processor of the Personal Information in the scenario described in this Policy, unless otherwise stated in the Product Privacy Notice.

1.How do We collect and use your Personal Information?

1.1 Types and purposes of the Personal Information We collect Personal Information

refers to all kinds of information relating to an identified or identifiable natural person that is electronically or otherwise recorded, excluding information that has been anonymized. When you use Chayora products or services or when you interact with Us, We may collect your Personal Information. We may collect different Personal Information depending on the product and service selected and the specific interaction. You are not necessarily required to provide your Personal Information to Chayora. However, in some cases, if you choose not to provide, Chayora may not be able to provide you with relevant products or services, neither be able to respond or solve the problems you encounter.

In the process of providing products or services, Chayora may also collect and aggregate statistical data such as website visits, application downloads, product sales, etc., in order to understand how users use Our products and services. For the purposes of this Policy, the above statistical data is considered as Non-Personal Information. We will endeavour to separate your Personal information from the Non-Personal Information and use both types of information separately. If Personal Information is mixed with Non-Personal Information, We will still consider such information as Personal Information and provide protection.

We will only process your Personal Information for the purposes described in this Policy and the Product Privacy Notice. The following table outlines the Personal Information We collect from you or from the third parties, as well as the purposes for which We collect such Personal Information.

Category of Personal Information别	Specific Personal Information	Purposes
Identity Information	First name, surname, gender, title, ID type and number, and personal portrait photo	》 Ensure physical security of Chayora data centres; 》 Ensure information security compliance; 》 Conduct business negotiations and establish cooperative relationships; 》 Manage and maintain business relationships, and perform contracts; 》 Allow access to Chayora online portal; 》 Provide you with corresponding products/services, or implement corresponding business functions; 》 System management and maintain up to date information in the system; 》 Marketing; 》 Address complaints; 》 When We process your order, We may send your Personal Information to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases; 》 Necessary for fulfilling legal duties or obligations; 》 Other circumstances stipulated by laws and regulations.
Contact Information	Mailing address, email address, telephone numbers, and company name
Data Centre Access Records	Dates, times and location of access to Chayora Data Centre; access credentials, including any biometric access credentials (vascular print, hand shape, iris scan, etc.); CCTV images of people entering the data centre and accessing the customer areas.	》 Ensure physical security; 》 Control access to Chayora data centre and customer spaces and provide access logs information to Chayora’s customers; 》 Incident reporting and investigations.
Marketing and Communications Data	Customers’ preferences in receiving marketing from Us and customers’ communication preferences	》 Evaluate and analyse market and customers; 》 Recommend products/services; 》 Advertising
Behavioural Data	Site access, page access, time spent on page, feature use and other patterns related to website flow and usage	》 Improve services and the quality thereof; 》 Troubleshooting; 》 Marketing; 》 Analyse user online behaviour and create user profiles.
Technical Data	Internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access this website or use Chayora’s services
HR Data	Personal information, contact information, and other related information collected in the context of an employment relationship	》 Recruitment; 》 Internal employee management.

We collect identity information and biometric data only for verifying user identity, and We do not collect any other sensitive Personal Information about you, including religious beliefs, specific identities, medical health, financial accounts, and whereabouts, etc., and personal information of minors under the age of fourteen. We do not intentionally collect Personal Information from minors for any purposes unless required by applicable laws and regulations. If it involves Personal Information of a minor, we will handle it strictly in accordance with the law. If you are a minor, please do not provide us with your Personal Information. If you become aware of any such situation involving the collection of Personal Information from minors, or if you are a guardian and discover such a situation, please notify us promptly so that we can take appropriate measures, including deletion, as necessary.

We only use your Personal Information for the above purposes, unless We reasonably believe that We need to use it for other reasons that are consistent with the original purpose.

1.2 How do We collect your Personal Information?

We collect and process Personal Information when you:

（1）We collect and process Personal Information when you:

（2）Visit Our website, mobile applications, and social media accounts;

（3）Voluntarily complete a customer survey or provide feedback on any of Our message boards or via email;

（4）Use or view Our website via your browser’s cookies;

（5）Access Our office areas, computer rooms, data centre, and access or use Our business systems;

（6）Use Our office facilities and network;

（7）Product/service improvement and upgrade;

（8）Third-party provision of information: where permitted by law, We may obtain your Personal Information from publicly available sources and may combine this information with your other Personal Information. If you use Our products or services through other third parties, or access Our website, mobile applications, social media accounts, business systems, etc., We may obtain Personal Information about you from such third parties, provided that We comply with legal requirements and obtain your Consent and authorization.

1.3 Our Basis for processing your Personal Information

We only process your Personal Information in the following circumstances:

（1）We need to perform a contract we are about to enter into or have entered into with you. For the processing of Personal Information of Our customer contacts, supplier contacts and service provider contacts, We rely on the performance of a contract with such party as well as on a reasonable and necessary purpose to use such Personal Information;

（2）It is necessary for the performance of legal duties or legal obligations;

（3）It is necessary to respond to public health emergencies or to protect your life, health and property or that of others in case of emergency;

（4）Personal Information is processed within a reasonable scope in order to carry out news reporting, supervision by public opinion and other activities in the public interest;

（5）Your Personal Information that has been disclosed at your own discretion or has been lawfully made public is processed within a reasonable scope;

（6）We have your specific consent to carry out the processing for the purpose in question (“Consent”);

（7）Other circumstances specified in laws and administrative regulations.

If the purpose, method, or type of processing Personal Information changes, We will update this Policy in accordance with Section 9 hereunder (Changes to this Policy).

1.4 If the purpose, method, or type of processing Personal Information changes, We will update this Policy in accordance with Section 9 hereunder (Changes to this Policy).

In some cases, We may need to collect or process your Personal Information in order to comply with the law or to perform under the terms of a contract We have concluded with you. If you fail to provide such information as requested or agree to Our processing, We may not be able to perform the contract We have entered or are attempting to enter into with you (e.g. providing you with access to Our data centres).

2.How do We entrust for processing, share, transfer, and disclose your Personal Information?

2.1 Entrustment Processing

In some cases, We will entrust other companies to process your Personal Information on Our behalf, such as answering hotlines, sending emails, or providing technical support on Our behalf. These companies can only use your Personal Information to provide you services on our behalf.

We will execute strict delegation processing agreements or personal information processing terms with the entrusted party. The entrusted party has the obligation to process relevant Personal Information in accordance with this Policy and Our instructions, and take relevant confidentiality and security measures to ensure the security of Personal Information.

2.2 Sharing

Sharing refers to We providing Personal Information to other personal information processors, and both parties independently decide on the purposes and methods of processing in their personal information processing activities. Usually We do not share your Personal Information with external parties, except in the following circumstances:

（1）Sharing upon your Consent: We will share the information within your authorized scope with a third party designated by you upon your Consent;

（2）Sharing under statutory circumstances: We may share your Personal Information in accordance with laws and regulations, or as required for litigation and dispute resolution, or required by administrative or judicial authorities pursuant to laws;

（3）Sharing to Our affiliates: your information may be shared with Our affiliates. We will only share your information with Our affiliates for specific, distinct and lawful purposes and only such information as is necessary to provide services;

（4）Sharing with business partners: We may share your Personal Information with third parties, such as partners, to guarantee the smooth service provision. However, We will only share your Personal Information for legality, rightfulness, necessity, specific and clear purposes, and only necessary for providing services. We will conduct security assessments on the sharing behavior and personal information recipients, and execute data protection agreements or strict confidentiality agreements with the recipients, requiring them to process Personal Information in accordance with this Policy and take relevant confidentiality and security measures.

2.3 Transfer

In the event that Personal Information is transferred in connection with a merger, division, dissolution, acquisition, bankruptcy, etc., We will inform you the name and contact information of the recipient in advance, requiring the recipient to continue to be bound by this Policy to process your Personal Information. If the recipient changes the original purposes and processing methods, it shall obtain your Consent again.

2.4 Disclosure

We will only disclose your Personal Information under the following circumstances:

（1）After obtaining your Consent; or

（2）Based on the requirements by laws and regulations, judicial proceedings, or the requirements from administrative authorities.

3.How does your Personal Information transfer cross border?

The Personal Information we collect within the territory of the People’s Republic of China (referred to as “PRC”) is generally stored within the territory of PRC. However, Chayora is a transnational corporation, which means your Personal Information collected by Chayora may be processed in or accessed from other countries/regions where Chayora or its affiliates, subsidiaries or service providers and business partners have institutions. Different countries/regions may have different data protection laws. When using Our products and services or providing Us with your Personal information, you consent to Our collecting, storing, transmitting, using, and processing your information outside of your country/region in accordance with this Policy. In such cases, Chayora will implement according to the requirements of applicable laws, take reasonable measures to protect your Personal Information, and ensure that Our processing of your Personal Information complies with the requirements of this Policy and applicable laws.

4.How to protect your Personal Information?

We are committed to ensuring that your Personal Information is secure. In order to prevent misuse, unauthorized access or disclosure, alteration and/or destruction, We have put in place appropriate technical, administrative, and security measures.

Our information security management system is designed and certified to an internationally recognized standard, ISO 27001:2013. All Chayora business systems and processes have also been certified as SOC2 Type 2, PCI, DSS, and HIPAA compliant. Systems and processes have been scrutinized for limiting access to only required personnel, and the proper protections and restrictions to physical accessibility have been implemented to secure your Personal Information from accidental loss and from unauthorized access, use, alteration or disclosure.

5.Retention period of Personal Information

The length of time Chayora may store your Personal Information may vary depending on our processing of your Personal Information. Unless otherwise required by laws, We will not maintain your Personal Information for longer than the shortest time that is necessary for the purposes for which information was collected.

6.Your rights

6.1 You are entitled to exercise the following rights over your Personal Information

Access your Personal Information. You have the right to access the copy of your Personal Information held by Us. If you request to transfer your Personal Information to other personal information processors designated by you, we will cooperate with the personal information processor designated by you and provide the means of transfer in compliance with the conditions stipulated by the Cyberspace Administration of the PRC.

（1）If the purposes have been fulfilled, cannot be fulfilled, or are no longer necessary;

（2）If you no longer use Our products or services;

（3）If We no longer provide products or services to you, or the retention period for your Personal Information has expired;

（4）If Our collection and processing of Personal Information breaches Our agreement with you;

（5）If Our processing of Personal Information violates laws and regulations.

（6）When the retention period for Personal Information specified by laws and administrative regulations has not expired, or when it is technically difficult to delete your Personal Information, We will stop processing activities other than storage and carrying out necessary protective measures.

Restrict the processing of your Personal Information. This enables you to ask Us to suspend the processing of Personal Information about you, such as when you want Us to establish its accuracy of or the reason for processing it.

Withdraw Consent. You have the right to withdraw your Consent for anything We do with your Personal Information based on your consent. Your decision to withdraw consent will not affect Our processing of Personal Information based on your prior Consent.

As certain functions of the website and the provision of certain products or services of Chayora rely on the processing of your Personal Information, if you withdraw your Consent, We may not be able to provide you with access to certain specific functionalities of this website or offer you other Chayora products or services.

We will advise you if this is the case at the time you withdraw your Consent.

6.2 How to exercise your rights?

If you wish to exercise any of your above rights or other rights granted to you by local laws, please contact us: compliance@chayora.com.

We generally do not charge a fee for your reasonable requests, but in cases of repeated requests or requests that exceed the reasonable limits, We will charge a certain fee depending on the situation. We may also refuse the requests which are excessive, technically challenging (e.g. need to develop new systems or fundamental changes to existing practices) or pose risks to the legitimate rights and interests of others or are objectively difficult to implement (e.g. involving information stored on backup tapes).

Please note that:

In some cases, We may demand that you provide Us with valid proof of identity for our verification before processing your request; and

Where your request involves additional facts (e.g. a determination of whether Our processing has complied with, or violated, applicable laws), We will investigate your request reasonably promptly and then decide what action to take, before We respond.

In accordance with legal and regulatory requirements, We may not be able to respond to your requests in the following circumstances:

（1）Directly related to national security or national defense security;

（2）Directly related to public safety, public health, or significant public interests;

（3）Directly related to criminal investigation, prosecution, trial, or execution of judgments;

（4）There is sufficient evidence to show your subjective malice or abuse of rights;

（5）Responding to your request would seriously harm legitimate rights and interests of you or other individuals and organizations;

（6）Involves trade secrets;

（7）Directly related to Our fulfillment of legal obligations stipulated by laws and regulations;

（8）Other circumstances stipulated by laws and regulations.

6.3 Marketing communication preferences

You can ask Us to stop sending marketing messages to you at any time by simply updating email preferences or unsubscribing links or by contacting us at any time using the contact details in the Contact Us section.

Please note that We may still contact you regarding the use of this website and/or Chayora's products and services when necessary.

7.Use Our website

7.1 COOKIES

Cookies are text files placed on your computer or mobile device that collect standard Internet log information and behavior information such as visitors’ browsing preferences. When you visit Our website, We may collect information from you automatically through cookies or similar technology.

Chayora uses cookies for the same purpose as most websites or Internet service providers do, that is to improve your online experience, including keeping you signed in, understanding how you use this website, etc.

Your information obtained by Chayora through cookies will be used for statistical analysis purposes only and will be removed from the system thereafter. You can choose to reject cookies by modifying your browser settings; however, under certain circumstances, your rejection may result in some services not functioning properly.

7.2 Links to other websites

Our website may contain links to other websites. We do not have any control over external websites, and their privacy or data protection policies. External sites are not governed by this Policy. Therefore, We are not responsible for the protection and privacy of any information which you provide when visiting such other sites. If you click on links to external websites, please read and refer to their privacy or data protection policies.

8.Disclaimer

In no event will We be liable for any information it merely transmits and does not collect from you during your use of Our products or services.

9.Changes to this Policy

We may update this Policy for provision of better service and to reflect changes in our business and operations. If this Policy changes, We will place any updates on our website(https://chayora.com). For significant changes, we may send notifications through different channels, such as publishing notifications on Our website or sending you separate notifications. If you do not agree with these changes, you may discontinue using Chayora’s products and services and cease all activities, such as accessing the website, business systems, office areas, etc.If you do not agree with these changes, you may discontinue using Chayora’s products and services and cease all activities, such as accessing the website, business systems, office areas, etc. If you choose to continue these activities, it signifies your agreement to be bound by the modified Policy.

10. Contact Us

If you wish to exercise your rights of data protection, or have any questions, suggestions, complaints, or requests regarding the Policy, you may reach out to us by emailing: compliance@chayora.com

We will generally respond within the time stipulated by applicable laws. If you are not satisfied with Our response, specifically if you believe that Our processing of your Personal Information has infringed upon your lawful rights and interests, you can also file a complaint or report to local privacy protection legislation.

Important notice:The Chinese and English versions of this Policy are available on this website. If there is any discrepancy between the two versions, the Chinese version shall prevail.

The latest version of this Policy is issued on【October 8 2024】.

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