Privacy Policy

1. Introduction

1.1Hangzhou Tongming Technology Co., Ltd. (hereinafter referred to as "the Company" or "we") is the operator of software such as WonderPen. This Privacy Policy (hereinafter referred to as "this Policy") describes how our company will collect and process your personal and private information. Our company is a company located in the People's Republic of China. We will strictly abide by the laws and regulations of the People's Republic of China and provide you with safe and reliable services.

2. Information we collect

2.1In order to provide you with our services, we need you to provide us with the information necessary to use the services. We will only collect information necessary to achieve specific, specific, clear and legitimate purposes, and will not further process this information incompatible with the above purposes. You have the right to choose whether to provide the information we request, but in most cases, if you refuse, we may not be able to provide you with corresponding services or respond to your questions.

3. Information you actively provide when using our services

3.1We receive and store any information you provide to us on our website/products or in any other way, including email, etc. You can choose not to provide certain information, but this may prevent you from using many of the services we provide.

4. Information we collect when you use the service

4.1When you use the services we provide, we may collect the following information:

• Device and application information. Information such as device model, device identifier, operating system version, signal strength, application version number, browser type and settings, etc.
• Log information. When you use our services or view content provided by us, we automatically collect and store certain information in logs. Such as service access address, access time, number of visits, visits
  IP, error crash information, network request information, etc.

5. Exceptions to obtaining authorized consent

5.1You fully understand and agree that our collection and use of your personal information does not require your authorization and consent under the following circumstances:

1. Related to national security and national defense security;
2. Relevant to public safety, public health, and major public interests;
3. Relevant to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and judgment execution;
4. To protect the safety of your life and property or that of others but cannot obtain your timely authorization under special circumstances;
5. Collect your personal information from other legal and public channels;
6. Other situations stipulated by laws and regulations.

6. How we use the collected information

6.1We strictly abide by the provisions of laws and regulations and our agreements with users, and use the collected information for the purposes described in this policy. We may use your personal information for the following purposes:

1. Provide personalized user services and content;
2. To manage our business;
3. Provide aggregate statistical information about our users to third parties;
4. Security protection for the purpose of preventing loss and fraud, assisting in identifying users, verifying identities, etc.;
5. Carry out relevant promotion activities;
6. Conduct data analysis, research and develop statistical information relating to the use of our services;
7. Store and maintain information related to you for our business operations or to fulfill legal obligations;
8. Send notification;
9. Improve user experience;
10. Other purposes with your consent;

7. How we use cookies and similar technologies

Cookies

7.1A cookie is a plain text file stored on your computer or mobile device by a web server. The contents of a cookie are retrieved or read by the server that created it. Each cookie is unique to your web browser or mobile application. Cookies often contain identifiers, site names, etc.

7.2We sometimes store cookies on your device. Our purpose of enabling cookies is to improve user experience, including login and authentication, storing your preferences and settings, statistical analysis, interest-based advertising, etc. You can manage, delete, and disable cookies according to your preferences. However, clearing or disabling cookies may affect your ability to use all or part of the services we provide.

Other local storage

7.3We may use other local storage technologies in some services, such as HTML5 local storage. These technologies are similar to the cookies described above in that they are also stored on your device and may be used to record certain information about your activities and preferences.

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

Share

8.1We will not share your personal information externally, except in the following circumstances:

1. After obtaining your explicit consent, we will share the information within the scope of your authorization with the third party designated by you;
2. We may share your personal information externally in accordance with laws and regulations, litigation and dispute resolution needs, or as required by administrative and judicial authorities in accordance with the law;
3. Your information may be shared within our affiliated companies. We will only share your information within our affiliated companies for specific, explicit and lawful purposes and will only share information necessary to provide the service;
4. Your information may be shared with our business partners to ensure the smooth completion of the services provided to you. However, we will only share your personal information for legal, legitimate, specific and clear purposes, and we will only share the personal information necessary to provide services.

Transfer

8.2We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

1. After obtaining your explicit consent, we will transfer your personal information to other parties;
2. When a merger, acquisition or bankruptcy liquidation is involved, if personal information is transferred, we will require the new company or organization that holds your personal information to continue to be bound by this statement, otherwise we will require the company or organization to re-sign You seek authorized consent.

Public Disclosure

8.3We will publicly disclose your personal information under the following circumstances:

1. After obtaining your explicit consent;
2. Public disclosure based on legal or reasonable grounds: We may publicly disclose your information when required by law, legal proceedings, litigation or public and government authorities.

9. How we store and protect your personal information

9.1We have adopted reasonable and feasible security measures that comply with industry standards to protect your information and prevent personal information from unauthorized access, public disclosure, use, modification, damage or loss.

9.2We will take reasonable and feasible measures to try our best to avoid collecting irrelevant personal information. We will only retain your personal information for the period necessary to achieve the purposes stated in this policy, unless there are mandatory retention requirements by law.

9.3The Internet is not an absolutely secure environment. When using the services we provide, we strongly recommend that you do not use communication methods that are not recommended by our official platform to send your information.

9.4Please note that the information you voluntarily share or even share publicly when using our services may involve your or others' personal information or even personal sensitive information. Please consider more carefully whether to share or even share relevant information publicly when using our services.

9.5After an unfortunate personal information security incident occurs, we will inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the handling measures we have taken or will take, and suggestions for you to prevent and reduce risks on your own. , remedial measures for you, etc.

10. Your rights

10.1We will do everything possible to adopt appropriate technical means to ensure the accuracy of the personal information collected about you and to ensure that it is updated in a timely manner. You can also access, correct and delete your personal information in accordance with our relevant policies and tips.

11. How we will handle the personal information of minors

11.1Our products and services are primarily intended for adults, but we are well aware of the importance of taking extra precautions to protect the privacy and security of minors who use our products and services. We consider anyone under the age of 18 (or the age specified by local law) to be a minor. We do not market specifically to children under 13 years of age.

11.2For the personal information of minors collected with the consent of the guardian, we will only use or disclose it when permitted by law, explicit consent of the guardian, or necessary to protect the minor. If at any time the guardian needs to access, modify or delete personal information related to the ward, please contact us as described in the "Contact Us" section of this policy.

11.3If we find that we have collected the personal information of minors without first obtaining verifiable guardian consent, we will try to delete the relevant content as soon as possible.

12. How to update this privacy policy

12.1We reserve the right to update or modify this statement from time to time.

12.2If such changes will cause a substantial impairment of your rights under this policy, we will notify you by placing a prominent notice on the page before the changes take effect. For major changes, we will also provide more prominent notices. In this case, if you continue to use our services, you agree to be bound by the revised policy. Major changes referred to in this policy include but are not limited to:

1. Our service model has undergone significant changes. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.;
2. We undergo major changes in ownership structure, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy mergers, etc.;
3. The main objects to whom personal information is shared, transferred or publicly disclosed change;
4. Significant changes in your rights to participate in the processing of personal information and how you exercise them;
5. When our responsible departments, contact information and complaint channels for handling personal information security change;
6. When the personal information security impact assessment report indicates that there is a high risk.

13. Contact us

13.1If you have any questions about this Privacy Policy, you can contact us by email at support@tominlab.com.