Beijing Tendcloud Tianxia Technology Co.,Ltd and its affiliates (hereinafter referred to as “we/us” or “TalkingData” collectively), as a company focusing on internet comprehensive data service, pays much attention to protection of personal information and privacy in data service all the time. When you visit TalkingData website or sign up for any product and service of TalkingData, we will comply with the legal and regulatory requirements and take appropriate security measures as much as possible to protect your personal information safe and controllable.
1、 Visit and Browse TalkingData Website
When you visit our website, like most websites, we will
- Use cookie technique to store conversation/selection information in your computer;
- Use clear gif/ Web Beacons/Web Bugs software technique to tell us which content is valid;
- Automatically collect certain information and store in log file. These information includes: Internet protocol (IP) address, browser type, Internet service provider (ISP), reference / exit page, OS, date/time stamp, click-data stream and so on.
We use these information to:
- Improve your website experience and service quality;
- Help us manage website content efficiently;
- Analyze group users’ on-site activities and social information of the whole users group.
2、 Overview of Usage of TalkingData Services
1） When you register TalkingData service，we will request your personal information, including name, company name, E-mail address, password, telephone number and QQ number to create new account. When you contact us afterward and use TalkingData service persistently, we may request more contact information from you, including:
- Postal address, telephone number, duty and position;
- Your company information, such as company name and business type;
- Your product information, such as mobile application name, content, type and certain character; promotion channel and others.
We may use these information to:
- Send you registration confirmation;
- Learn and manage account;
- Respond your service requirement of clients;
- Learn your company’s requirements and requirements of products, so as to determine applicable product and service;
- Contact you for marketing and promotion purpose, and provide you with more information about our product;
2） You can contact us with our E-mail left on the website. You may provide personal information when you contact us by E-mail, and we will use these information to respond your question and service requirement, and so as to upgrade our website and services.
3、 Details for Usage of TalkingData Services
1） TalkingData Analysis Service
TalkingData provides data statistics analysis service for mobile application through your integration of TalkingData data SDK and API in application. Your application will collect and transfer relevant data of your terminal users through technical means, and our service will help analyze these data to learn the performance and user’s usage situation of your application on different terminal equipment, platform or application distribution channel.
Your terminal users’ data usually include but not limited to, SDK or API version, platform, time stamp, application mark, application version, application distribution channel, iOS IDFV, iOS IDFA, Android advertiser mark, MAC address, IMEI equipment model, terminal manufacturer, terminal equipment OS version, conversion start/end time, language residence, mobile network/country code, time zone and network situation (WiFi and so on), hardware, CPU and battery usage situation and so on.
In accordance with your mobile application type and your requirement on statistical analysis, your terminal users’ data may also include: user’s gender, age, location, equipment information, OS, operator, promotion channel, trigger event, mistake report and volume of page view and so on.
For the purpose of analysis service, TalkingData analysis service will send above data to TalkingData server through your application, and display in convergent data and analysis report. You could check relevant statistics and analysis result through logging in account on our website.
2） Industry Report Service
We will build TalkingData database based on data collected by analysis service and by other legal means, and make analysis report about application’s performance evaluation or behavior pattern (hereinafter referred to as “industry report”) in publisher, industry, certain area and market. Industry report will be displayed in unidentified convergent way, including those published by TalkingData itself and those customized in accordance with your requirement.
Under special situation, we also make evaluation result about application of certain type or kind in accordance with TalkingData’s statistic model. Such evaluation result may present certain coincidence with your application because of data acquired from your application, however, these evaluation result are made based on our statistic model for the purpose of evaluation which is convergent and anonymous.
3） TalkingData DMP
We will build TalkingData database based on data collected by analysis service and by other legal means, and form TalkingData’s TDID through converging, washing, calculating, and so as to build huge third party group data center. Such center will divide mobile terminal users into different groups by character and hobby, and provide group mark information for all practitioners by open interface, in order to optimize launch and improve marketing effect.
Users could match TDID through TalkingData DMP and buy the corresponding mark information. These mark information are obtained through collecting large amount of mobile application users’ data, anonymization and intelligent operation, and ultimately displayed in statistical analysis data, contains no personal privacy or identifiable data.
4） Commercial Cooperation with the Third Party
Besides the service we provide in the form of TalkingData DMP, we also cooperate with a third party in various ways to utilize the data collected processed and handled through TalkingData DMP, which include but not limited to cooperate with advertiser, advertising alliance or advertise agency to optimize advertisement launch and improve marketing effect. Such data we shared with the third party contains no personal privacy or identifiable features.
5） Smart Data Market
We are providing service named Smart Data Market for both data service provider and data demander and such Smart Data Market aims to facilitate the online transaction of data as well as its derivatives (referred to as Data Products, no matter in form of data API, tools or Application software) which are produced and/or processed by TalkingData itself or authorized to deal by the third lawful rights owner.
It is guaranteed that Data Products produced and/or processed by TalkingData itself are clear of ownership and in compliance with relevant laws and regulations about personal information protection. In general, the Data Products which are transacted or authorized in Smart Data Market are de-identification ones. Under some special circumstances when personal information data may be accessed, it is required that explicit authorization be received from related person and the using of such data be limited within the specific range. Meanwhile, we are trying our best with reasonable discretion to require the third data owner to guarantee its Data Products meet the requirements above.
We provide Solution, PSO and Big Data Lecture.
When providing these services, we may ask you to provide more personal information to understand your business or product situation, please decide cautiously whether to provide according to your demands.
Pursuant to relevant laws and regulations, it is not necessary to obtain your authorization to collect your personal information in the following cases:
1) Related to national security and national defense safety;
2) Related to public safety, public health and major public interest;
3) Related to criminal investigation, prosecution, trial and enforcement of judgments;
4) To avoid legal emergency and fail to obtain your consent in time;
5) For purpose of academic research and related outcomes have been de-identification;
6) The information we collect is from which is made public by yourself;
7) The information we collect is from which is publicly and legally disclosed;
8) To fulfill the contract you have signed;
9) Other circumstances as prescribed by laws and regulations.
You are clearly aware of that, you need us to collect, store and process personal information from terminal user of your application, for the purpose of our data statistics and analysis. Therefore, you must undertake:
1） You have obtained fully necessary authorization, consent and permit from terminal users, for the purpose of our performance of service;
2） You have obtained fully necessary authorization, consent and permit from terminal users for us in order to anonymously and convergently process, transfer (including possible international transfer) the data we collected;
3） You have complied and will comply with applicable laws, regulations and supervisory requirement, including but not limited to formulate and publish policy relevant to personal information protection and privacy protection.
4） You should make the disclosure and explanation to the end user, allowing us to transfer our collected data to the third parties for Internet targeted advertising purposes on the condition that anonymous and polymerization processing have been made with respect of such data information before transfer. You should also provide end users with easy-to-operate selection mechanism, indicating how and when the user may exercise the option and how and when the user can modify and withdraw such option, so that the user can choose to agree or disagree with the collection and use of his/her information and transfer of such information to the third parties for Internet targeted advertising purposes.
You shall be liable for the comprehensive settlement and compensation to us for our possible loss in any kind, if you violate the commitment above and thus causing your terminal user’s claim or right request against us in any kind, or causing us to be involved in legal or administrative procedure.
We will try our best to take appropriate technical measures to safeguard your access, updating and correction of your registration information or any other personal information you provided when using TalkingData Service.
You can access your personal information by going to the "Account Management" page and logging in to your account, except as provided by laws and regulations.
2、 Correct and/or Supplement
When you find there is any mistake about your personal information we collect or there should be update about your personal information, you can log in the "Account Management" page and correct or update by yourself.
Your choice to close your account or click the OPT-OUT on the TalkingData website would be deemedthat you choose to withdraw your authorization. We would stop collecting your personal information and delete your personal information. Please understand that we may not delete your personal information immediately from the backup system, but will delete your personal information when the backup is updated.
You can request TalkingData to delete your personal information in following cases:
1) We deal with your personal information in a way which violate laws, regulations or agreement with you;
2) We collect and use your personal information without your explicit consent;
3) We and/or You terminate the services between You and TalkingData.
If we decide to respond to your request for deletion, we will also, as soon as possible, notify the third party which we have share your information to delete your personal information, unless this kind of party has acquired your authorization, or other contrary provisions in law.
If you are unable to access, update or delete your personal information through the above path, you may contact us through TalkingData Customer Service at any time. We will respond to your request within 15 days.
Notwithstanding the above provisions, we may keep certain data for reasonable term within the limit allowed by law for dispute settlement, users’ agreement performance and compliance with technical requirements related to safe operation.
1、Security Measures for Data
No transfer means or digital storage means on the internet is 100% safe. Although we have made reasonable efforts, there are still risks of loss to your’s and your user’s person, property and reputation caused by theft, illegal possession or abuse. You have learnt the risks above and would like to undertake them.
We will comply with general and reasonable standard of industry to protect the safety and confidentiality of information we have stored. Including but not limited to: firewall and data backup measure; limited access to data center; confidential agreement with employee and security management system; hash processing to identification information of mobile terminal.
We have set up the data security management system and improved continuously, including the classification of user information, encryption and preservation, data access rights division, the designated internal data management system and operating procedures. We have strict process in data acquisition, use and destruction to avoid your personal information is illegally used.
We have also established a training mechanism that regularly organizes safety and privacy protection training to raise awareness of employees' personal information protection. We also periodically review, update and disclose the TalkingData Security Risk and Personal Information Security Impact Assessment Report.
2、Emergency and Early-warning
If there is security incidents going on, we will promptly inform you that the basic situation and possible impact of the security incidents, the emergency response that we have taken or will take, other related measures for disposal and remedial measures for you through the station letter / your reserved contact information in accordance with relevant laws and regulations. If it is difficult to inform everyone, we will take reasonable and effective way to issue announcements and we will voluntarily report the security incidents as well as the disposal to relevant regulatory authorities.
If you find any leakage in your personal information, please immediately contact us and we would take appropriate measures in time.
We have mentioned in precondition of the services that we refuse to have juveniles registered as our users. We will not collect and use juveniles’ data if we knew.
If your application is designed and developed for juveniles, please ensure that the terminal user’s registration and usage of application is conducted by guardian of juveniles.
Except for the situation provided hereof, your data will not be disclosed and shared to third party in an identifiable way. However, situations below are exceptions:
1、 Having Obtained your prior consent;
2、 Required by judicial, administrative or other legal procedure;
3、 In the limited circumstances, we may engage the third party provider, consultant or other service provider to provide the work for us with the necessary maintenance, who has executed necessary terms with us to protect safety and confidentiality of data.
4、 In case of emergency, to protect the safety and legal rights and interests of us, our agents, clients, terminal users or others, after reasonable judgment.
5、 We file a sue or arbitration to defend the rights and interests of ourselves or other users.
6、 We are conducting or contemplate to conduct material changes such as mergers and acquisitions, reconstruction, sale of all or part of the share and/or asset, including but not limited to due diligence process.
Based on the personal information that is legally collected, automatic decision-making (such as commercial information push) is implemented through tagging or profile processing through non-manual automatic decision-making techniques such as information systems and algorithms. The behaviors above make your personal information unidentifiable, and can not be deemed as sharing, transferring or disclosing any of your personal information to any third party. If you do not want to be part of this type of placement, you can opt-out via the OPT-OUT channel (http://www.talkingdata.com/optout.jsp?languagetype=en_us).
During the process of service provision, we may transfer the data obtained from you or your product terminal users to our affiliated entity or other third party outside your jurisdiction, and such transfer will be handled to the extent permitted by applicable laws and regulations and provide adequate protection of your personal information in accordance with this policy. If you or your product terminal user is located beyond jurisdiction of PRC, or when you and your product terminal user is in jurisdiction of PRC while we need to transfer it to the place outside of jurisdiction of PRC, you shall consent or obtain consent from terminal user for this international transfer.
We highly advise you to consult local professionals to ensure this transfer complying with local data-protection requirement. Especially, when the international transfer involves EU and USA area, please pay attention to the legal regulation for personal information data protection of these countries and areas.
This policy is an important part of TalkingData Terms of Services.
This policy shall be interpreted and governed by the law of PRC. Dispute in any form between you and TalkingData shall be settled through amicable negotiation. Where it fails, either party has the right to submit the dispute to Beijing Arbitration Commission for arbitration in Beijing in accordance with its arbitration rules effective then.
If you are not satisfied with our response or you think we deal with your personal information in a way which infringe on your legal rights and interests, you could complain or report to the regulatory authorities such as Netcom, Telecom, Public Security and Industry and Commerce, or start the dispute process according to Article Ⅸ.