Updated on: May 11, 2024
Effective from: May 11, 2024
This Policy applies to DMS CORPORATION (Registered address: Room 812, Floor 8, Huakong Building, Building 3, Yard 1, Shangdi East Road, Haidian District, Beijing, hereinafter referred to as "We").Welcome to use our products and services. We understand the importance of your personal information and recognize that its effective protection is fundamental to the health and sustainability of our business. Your trust is paramount. We are committed to protecting the security and control of your personal information in strict compliance with applicable laws and regulations and by implementing appropriate security measures. This eZWalker APP Privacy Policy (hereinafter "this Policy") is designed to help you understand how we collect, use, share, store, transfer, disclose, and protect your personal information when you use our products and services. It also explains your rights to access, copy, correct, supplement, and delete your personal information, and how to exercise those rights.
Please carefully read and understand this Policy, particularly the provisions marked with an asterisk (*), in bold, or both, before using our products or services. By using our products or services, you agree to this Policy. This Policy is intended to be clear and transparent in explaining our privacy practices, including the meaning of technical terms. If you have any questions or comments about this Policy, please contact us using the information in Section 8.
By clicking or checking the box to agree to this Privacy Policy, you acknowledge that you understand the features of the Application, the necessary personal information collected to enable these features, and consent to the collection and use of this information. If you do not agree to this Privacy Policy, you will not be able to use the Platform Services. In addition to this Privacy Policy, We may provide supplemental notices regarding the purpose, scope, and methods for processing specific personal information in particular contexts. Such supplemental notices, which may be presented via pop-up windows, web pages, or other means, shall form a part of this Privacy Policy and have equal force and effect. If you have any complaints or concerns regarding the security of personal information, or any questions, comments, or suggestions about this Privacy Policy, please contact us using the information provided in Section 8. This Privacy Policy will help you understand the following:
I. Definition and Scope of Application
II. Collection and use of personal information
III. Third-Party Data Recipients and Sharing, Transfer, and Public Disclosure of Personal Information
IV. Your rights
V. Information storage
VI. Policy updates
VII. Protection of minors
VIII. Contact Us
I. Definition and scope of application
(I) Definition
1. eZWalker APP Service Provider: DMS CORPORATION, a company duly organized and existing under the laws of [Jurisdiction of Incorporation], which researches, develops, and provides the eZWalker APP products and services (hereinafter referred to as “We” or “Us”).
2. eZWalker APP User: An individual who registers an eZWalker APP account (hereinafter referred to as “You”).
3. Personal Information: Information recorded in any form (including electronic form) that can be used, either alone or in combination with other information, to identify an individual.
4. Sensitive Personal Information: Personal information that, if disclosed or used unlawfully, could reasonably be expected to cause substantial harm to an individual, including harm to their dignity, or endanger their safety or security (including physical, property, or financial security). Sensitive personal information includes, but is not limited to, biometric data, religious beliefs, specified identities, medical and health information, financial account information, location data, and the personal information of children under the age of fourteen (14).
5. Child: A person under the age of fourteen (14).
6. Deletion: The act of removing personal information from systems involved in the performance of daily business functions, rendering such information irretrievable and inaccessible.
7. De-identification: The process by which personal information is processed so that it can no longer identify a specific individual without the use of additional information.
8. Anonymization: The process by which personal information is processed so that it can no longer identify a specific individual and cannot be restored.
9. Personal Information Processor: An organization or individual that determines the purposes and means of the processing of personal information.
Unless otherwise defined, the terms used in this Policy have the same meanings as in the eZWalker APP Service Agreement.
(II) Scope of application
This Policy applies to the eZWalker APP product and services. If our related products or services utilize the eZWalker APP and do not have a separate privacy policy, this Policy also applies.
II. Collection and use of personal information
When you use the eZWalker APP and/or its services, we may collect and use the following two types of your personal information (or require the following permissions):
1. To provide you with basic access to our products and/or services, you must authorize us to collect and use the necessary information (or enable the appropriate permissions). If you refuse to provide the relevant information or enable the necessary permissions, you will not be able to properly use our products and/or services.
2. To provide you with the basic functionality of our products and/or services, you must authorize us to collect and use necessary information (or grant us the necessary permissions). If you refuse to provide the relevant information or enable the necessary permissions, you will not be able to properly use the additional features or achieve the intended functionality.
We are committed to providing a diverse range of products and services to meet your needs. Because we offer a variety of products and services, and different users may choose to use different ones, the specific features, including basic and additional functionality, and the types and scope of personal information we collect and use may vary depending on the product or service. Please refer to the specific product or service documentation for details. To enhance your product and service experience, we continually improve our technologies. This may involve introducing new or updated features that require us to collect and use new categories of personal information or change the purposes or methods for processing your personal information. We will notify you of any changes to the purposes, scope, or methods of collection and use of such information through updates to this Policy, pop-up notifications, or in-app messages. We will provide you with a clear method to consent to such changes and will only collect and use the information after obtaining your explicit consent. If you have any questions, comments, or suggestions during this process, you can contact us using the contact information provided in [Section VIII]. We will respond as soon as possible and within the time frame stipulated by laws and regulations.
We will collect and use your personal information only for the purposes described in this Privacy Policy and in accordance with the principles of lawfulness, fairness, and necessity. Please note that if you provide personal information of another individual, you must ensure you have obtained their authorization. We reserve the right to verify the legitimate source of such personal information at any time.
(I) eZWalker APP User Registration and Account Management
1. eZWalker APP User Registration
When registering for an eZWalker APP account (whether by invitation or open registration), you must provide your mobile phone number issued within the People’s Republic of China and create a login password. If you reside outside of China and are unable to provide a mobile phone number issued within China, you may register using an email address through our English-language registration interface. The mobile phone number or email address you provide will be used to receive verification codes for registration, login, account linking, and password recovery. It will also serve as a designated contact method for receiving communications from the eZWalker APP, including notifications about new features, service updates, and other important information. If you are only browsing or searching the DMS website for information about the eZWalker software, its features, and services, you are not required to register as an eZWalker APP user or provide the aforementioned information.
2. Additional services
After registering as an eZWalker APP user, you may choose whether to provide a profile picture and username. Any profile picture and username you provide will be publicly visible. You may also provide additional details, such as nickname, gender, date of birth, employer, and job title. These additional details will not be publicly visible.
(II) Inviting team members
When using the “Team Management” feature to invite members, you must provide us with the mobile phone number of each prospective member. You represent and warrant that you have obtained the necessary authorization from each individual. We reserve the right to verify the legitimate source of this personal information at any time.
(III) File upload, download, storage and sharing services
To provide file uploading, storage, and downloading services, you must grant us access to read, write, and store local files. To provide the photo upload feature, we require permission to access your camera. We also use the light sensor to determine if there is sufficient light for taking photos. When you share a file from the eZWalker APP to another application, eZWalker APP accesses your list of installed applications to launch the selected application and complete your request.
To download files you have stored in the cloud to your device, we require permission to write to your device’s storage. To download photos to your device, we require permission to write to your photo library. This permission is required to download files to your device. If you do not grant this permission, you will be unable to download files.
To facilitate file sharing and allow you to view files shared by others, we require permission to access your clipboard. This permission allows us to place sharing links onto your clipboard and allows the eZWalker APP to read these links so you can view the shared content. The eZWalker APP does not store or use your clipboard information for any other purpose.
(IV) To Provide Online Audio and Video Playback, and Online Document Viewing
To provide offline and online previews of local model files, we require permission to access your device’s storage. This allows us to cache these files for viewing.
(V) In-app search function
You can use the eZWalker APP's search function to find information about product features and files. To facilitate the use of this function, we will collect your search history and display it under "Recent Searches". You can delete your search history at any time by clicking the Delete icon. This action will not affect your use of the search function.
(VI) Message notifications
While you use the eZWalker APP, we may send you messages, such as service notifications, identity verification, and security alerts, through various means, including SMS messages, push notifications, pop-up alerts, and email. If you do not want to receive service messages, you may close them by clicking "Close" or a similar button in the pop-up message. To deliver certain information (such as account login and logout notifications) to the correct user within the application, we require access to your phone's state to obtain a unique device identifier.
(VII) Customer service and dispute handling
When you contact our customer service personnel or reach out to us using the contact information in [Section VIII], you are required to provide us with the necessary personal information to authenticate your user identity in order to safeguard the security of your account and system.
To facilitate communication with you and to promptly address and document the resolution of any issues, we may retain records of your communications and calls with us, including account information, any additional information you provide to substantiate relevant facts, and your contact information. To facilitate prompt diagnosis and resolution of technical issues, we may also request access to your client log information. This information is necessary to provide after-sales services. Failure to provide this information will prevent us from verifying your identity or identifying the issue, and thus, from providing you with service.
(VIII) Personal information automatically collected to ensure operational safety
To provide eZWalker APP products and services, enhance system security, protect account security, and fulfill our network security obligations as a network operator, we collect the following information to analyze platform system issues, monitor traffic, identify and mitigate potential risks, and prevent fraudulent activities. We collect information about your device type, device model, application crashes, service logs, device identifiers (Android ID, OAID, IDFA), installed application list (limited to this application’s package name and version number), operating system, and network information (IP address, BSSID). We use and integrate this information with your account and transaction data to assess account risk, verify your identity, detect and prevent security incidents, and implement legally required recording, auditing, analysis, and disposal measures. This information is required to use our basic functions.
(IX) Device permissions
The required device permissions for each feature are described within the individual feature descriptions. By enabling any permission, you authorize us to collect and use relevant personal information to provide the corresponding service. Disabling a permission withdraws this authorization, and we will no longer collect or use personal information based on that permission, nor will we be able to provide the corresponding service. Revoking a permission does not affect prior collection and use of information pursuant to your authorization.
(X) Cookies and similar technologies
Cookies, device information identifiers, and similar technologies are commonly used on the Internet. When you use the eZWalker APP services, we may use these technologies to send one or more cookies or anonymous identifiers to your device to collect and identify information regarding your access to and use of this product. We will not use cookies for any purpose other than those described in this Privacy Policy. We use cookies and similar technologies primarily to enhance your user experience, such as by saving you from repeatedly entering personal information, and to ensure the security of our products and services, including verifying your login status and account security. These technologies also help us improve service efficiency and speed up login and response times.
III. Partners involved in the use of data and the sharing, transfer, and public disclosure of personal information
(I) Partners Engaged in the Use of Data
1. Basic principles
We will adhere to the following principles when working with our partners:
1)Legality, Legitimate Purpose, and Data Minimization: We process data only where we have a lawful basis, for a specified, legitimate purpose, and limit processing to the minimum amount of data necessary to fulfill that purpose.
2)Transparency and User Choice: We respect users' rights to be informed about and control the processing of their personal information.
3)Security: We implement appropriate security measures to protect personal information. We carefully assess the purposes for which third parties will use the data, evaluate their security practices, and require contractual commitments to protect personal information.
2. Scope of partners
The scope of partners will include our affiliates and third parties if specific functions and scenarios involve services provided by them.
(II) Sharing
We do not share your personal information with any company, organization, or individual, except in the following cases:
1. With your express authorization and consent: For the purpose of this Privacy Policy, We will share the personal information within the scope of your authorization with our partners after We obtain your separate authorization and consent.
2. Where it is necessary to perform the statutory duties or obligations: We will share your personal information in accordance with the laws and regulations or as required by the administrative or judicial authorities.
3. When We cooperate with the third-party software development kit (service provider): We may access the following software development kits ("SDKs") provided by the third parties to provide You with the services. We will exercise our duty of care to strictly monitor the SDKs through which the partners acquire information to protect the security of your personal information.
4. In other circumstances provided for by laws and regulations.
(III) Entrusted processing
We may entrust an authorized partner to process your personal information, enabling them to provide you with certain services or perform functions on our behalf. We will only entrust the authorized partner with the processing of your information for the legal, legitimate, necessary and clear purposes stated herein, and the authorized partner may only access the information necessary for its performance of the functions. We will also require the authorized partner through an agreement to not use this information for any other purpose beyond the scope of entrustment. If the authorized partner uses your information for any purpose that is not entrusted by Us, a separate consent shall be obtained from You.
(IV) Transfer
We will not transfer your personal information to any company, organization or individual, except in the following cases:
1. With your prior express consent or authorization;
2. If required to do so by applicable laws and regulations, legal procedures, and mandatory administrative or judicial requirements; As required by applicable law or legal process;
3. In the case of mergers, acquisitions, asset transfers, or similar transactions, if such a transfer involves your personal information, we will require the new entity holding your personal information to continue to be bound by this Privacy Policy. Otherwise, we will request the new entity to seek your authorization and consent again.
(V) Public disclosure
We will only publicly disclose your personal information in the following circumstances:
1. We may publicly disclose the personal information specified by You based on your active choice and any other separate consent;
2. We may be compelled to disclose your personal information pursuant to legal or regulatory requirements, including mandatory administrative or judicial process. Any such disclosure will be limited to the information specifically requested and made in accordance with the applicable legal process.
3. When announcing penalties for account violations, we will disclose relevant account information, including account identifiers and details of the violation.
(VI) Cessation of Operations
Upon discontinuation of any product or service, We will cease collecting your personal information. We will notify you of the discontinuation individually or by public announcement. We will then delete or anonymize personal information we hold relating to the discontinued product or service.
(VII) Circumstances Exempting Consent Under Applicable Law
Under applicable laws, regulations, and national standards, your consent is not required for the following uses or disclosures of your personal information by Us or our partners:
1. Where necessary for the formation and performance of a contract to which you are a party;
2. Where necessary to comply with a legal obligation: We may share your personal information as required by law, legal process, litigation, or dispute resolution, or at the request of administrative or judicial authorities.
3. Where it is necessary to respond to public health emergencies or to protect the life, health and property security of natural persons in case of an emergency.
4. We may process your personal information to the extent reasonably necessary to conduct news reporting, public opinion supervision, or other activities in the public interest.
5. We may process your personal information that you have made manifestly public or that is already lawfully available to the public (e.g., through legitimate news reports or government disclosures).
6. In other circumstances provided for by laws and administrative regulations.
IV. Your rights
To facilitate your access, rectification, erasure, and other rights regarding your personal information (including withdrawing consent and account deletion), We provide convenient settings within the eZWalker APP. You may also exercise these rights by contacting us as described in Section VIII of this Privacy Policy. We will respond to your request in accordance with applicable law.
(I) Access, Rectification, Correction and Supplementation
You may access, rectify, and supplement your information (e.g., profile picture and nickname) by logging into the eZWalker APP and navigating to "Personal center - Account information".
To access other personal information generated during your use of our services, or to obtain a copy of your personal information, please contact us. We will respond to your request in the manner and within the time frame set out in this Privacy Policy.
(II) Deletion
If within the same document: "You may delete some of your information as described in Section 1 (Access, Rectification, Correction and Supplementation)."
You may request deletion of your personal information by contacting customer service in the following circumstances:
1. If our processing of your personal information violates applicable law or regulation;
2. If we collect and use your personal information without your express consent;
3. If our processing of personal information seriously violates our agreement with you;
4. If we stop providing products or services, or the storage period has expired.
If we decide to honor your deletion request, we will also use reasonable efforts to notify any third parties who obtained your personal information from us and request that they delete it promptly (unless otherwise required by applicable law or such third parties have independently obtained your authorization).
After you delete relevant information, or we assist you in doing so, we may be unable to immediately remove corresponding information from backup systems due to applicable legal and technical limitations. In such cases, we will securely store your personal information and restrict further processing until the backup can be erased or anonymized.
(III) Changing the scope of your authorized consent
You may submit a request to modify the scope of your consent using the contact information in Section VIII of this Privacy Policy. However, please understand that we may be unable to fulfill your request for certain types of personal information, such as information necessary to perform the eZWalker APP User Agreement or comply with applicable law.
If you withdraw your consent, we will no longer process the corresponding personal information. However, withdrawing your consent will not affect the prior processing of your personal information based on your consent, nor will it affect processing necessary to perform the eZWalker APP User Agreement or comply with applicable law.
(IV) Account deletion
You may delete your account by accessing [My - Account & security - Delete account] or by contacting us using the contact information in Section VIII of this Privacy Policy. Please note that if you cancel your account, we will delete or anonymize your personal information, unless otherwise required by applicable law or regulation.
If you delete information, or we assist you in doing so, we may be unable to immediately remove corresponding information from our backup systems due to applicable legal or technical limitations. In such cases, we will securely store your personal information and restrict further processing until deletion or anonymization is possible.
Please note that your deletion of the platform account will not affect our continued processing of your personal information to the extent necessary for the performance of theeZWalker APP User Agreement, or as required by applicable laws and regulations.
(V) Rights of the Deceased's Immediate Family
Subject to applicable law, unless you have made other arrangements, your next of kin may exercise rights to access, copy, correct, and delete your personal information by contacting us as set forth in Section VIII of this Privacy Policy.
(VI) Responding to your requests
If you, your guardian, next of kin, or other authorized party wish to make the aforementioned requests, or to exercise your rights regarding personal information under the laws of the People's Republic of China and other applicable laws, you may contact our customer service personnel or file a complaint directly with our personal information protection department. We will respond to You within 15 working days.
To ensure the security of your account and personal information, when you make the aforementioned requests, we may first verify your identity (such as through SMS verification codes, additional account verification, requesting a written request, or other reasonable means), before processing your request.
We generally do not charge fees for reasonable requests. However, for repeated or excessive requests beyond reasonable limits, we may charge a fee at our discretion. We may refuse requests that are not directly related to your identity, are made without reasonable grounds, require excessive technical resources (such as developing new systems or fundamentally changing existing practices), pose a risk to the legitimate interests of others, or are impractical.
Please be aware that we may not respond to your request under the following circumstances:
1. Related to the personal information processor's compliance with legal and regulatory obligations;
2. Directly related to national security or national defense;
3. Directly related to public safety, public health, or a significant public interest;
4. Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;
5. The personal data processor has sufficient evidence that the personal data subject has malicious intent or is abusing their rights;
6. Necessary for the purpose of protecting the life, property, or other significant legal interests of the personal information subject or another individual, where obtaining the individual's consent is not reasonably practicable.
7.Responding to the request would cause substantial harm to the legitimate interests of the personal information subject or another individual or organization.
8. The request involves trade secrets.
V. Information storage
(I) Storage period
We will retain your personal information only for as long as necessary to fulfill the purposes set forth in this Policy, unless a longer retention period is required or permitted by law. Pursuant to the Cybersecurity Law, network operators shall retain relevant network logs for not less than six months.
We determine the storage period of personal information based primarily on the following criteria:
1. Completing transactions with you and maintaining corresponding transaction records to address any inquiries or complaints you may have.
2. Enterprise file management requirements.
3. Whether you agree to a longer retention period.
4.We may need to present evidence to a court in potential litigation.
5. Whether there are any other agreements or legal requirements regarding the retention period.
After the retention period, we will delete or anonymize your personal information as required by applicable law.
(II) Storage location
Personal information generated or collected by us in the People's Republic of China is, in principle, stored on servers in China. We will not transfer any of your personal information outside of this jurisdiction without your express consent or unless required to do so by applicable law.
(III) Storage security
1. Technical measures for data protection
We have implemented reasonable and appropriate security measures consistent with industry standards to protect your information against unauthorized access, disclosure, use, alteration, damage, or loss. For example, we utilize industry-leading security measures for data storage; employ SSL protocol encryption for data access, providing secure HTTPS access; implement various security auditing schemes and anti-theft measures for data sharing; utilize trusted protection mechanisms to prevent malicious attacks on personal information; and deploy access control mechanisms to ensure that only authorized personnel can access personal information.
2. Organizational measures for data protection management
We have established an industry-leading data security management system centered on data and covering the entire data life cycle. This system enhances the security of personal information through organizational development, policy design, personnel management, and product technology. We have established a dedicated personal information protection department. We reinforce our employees' understanding of the importance of personal information protection through ongoing training programs and assessments.
3. Response to personal information security incidents
If our physical, technical, or administrative safeguards are compromised, resulting in unauthorized access to, disclosure, alteration, or destruction of information, and causing harm to your legitimate rights and interests, we will promptly activate o or a significant public interestur incident response plan and take reasonable and necessary measures to mitigate the impact on you. In the event of a personal information security incident, we will, in accordance with applicable laws and regulations, inform you of the basic details of the incident and its potential impact, the measures we have taken or will take, recommendations for mitigating risks, and any available remedies. We will notify you via SMS, telephone, push notification, and other reasonable means. If individual notice is impracticable, we will provide notice by reasonable and effective means such as posting a general announcement. We will also report the handling of personal information security incidents to the relevant regulatory authorities as required.
4. Prevention of account security risks
Please understand that due to technological limitations and the potential for malicious activity, we cannot guarantee absolute information security, despite implementing measures required by applicable laws, regulations, and standards. If you believe your personal information, especially your account or password, has been compromised, please contact our customer service representatives immediately or contact us via the contact information in Section VIII so that we may take appropriate action. You may also manage your account security settings such as "Change your bound phone number", "Change your password" and "Login device management" under "My - Account & security".
VI. Policy updates
We continually strive to improve our products, services, and technologies to provide you with a better experience. When we launch new services or change certain business processes, we may update our Privacy Policy to inform you of these changes. However, without your express consent, we will not limit your rights under this Policy. We will post any changes to this Policy on a dedicated page.
For major changes, we will also display the updated portions and the revised privacy policy to you through pop-ups, push notifications, or other means when you log in or update the version.
Major changes referred to in this Policy include, but are not limited to:
1. A material change to the product's business model. For example: The purposes of processing personal information, the types of personal information processed, and the manner in which personal information is used;
2. A material change in ownership structure or organizational structure, including a change in the parties to the Privacy Policy resulting from a business adjustment, transaction, or merger.
3. A change in the primary recipients to whom personal information is shared or publicly disclosed.
4. A material change in users' personal information rights and the manner in which those rights are exercised.
5. Changes to the contact information of the individual responsible for personal information protection or to the complaint channels.
6. When the personal information protection impact assessment report indicates a significant impact on individual rights and interests.
VII. Protection of minors
Our products and services are offered to adults with full civil capacity. We do not proactively collect age information to verify whether users are minors. However, if we are notified or otherwise become aware that we have inadvertently collected personal information from a child, we will promptly delete it.
VIII. Contact Us
You may contact us using the following methods, and we will respond to your request within 15 business days:
If you have any comments, suggestions, complaints, or reports regarding this Agreement, this Service, or personal information security, please submit your feedback through the feedback window or contact the personal information protection department of DMS CORPORATION.
Contact number: 400-016-0989
Contact address: Room 812, Floor 8, Huakong Building, Building 3, Yard 1, Shangdi East Road, Haidian District, Beijing.