Update Date: October 1, 2018

Effective Date: October 7, 2018

[TownSteel Inc.] (Here referred to as "we") understands the importance of personal information to you and will do its utmost to protect your personal information. We are committed to maintaining your trust in us and to abide by the following principles to protect your personal information: the principle of consistency of powers and responsibilities, the principle of clear objectives, the principle of choice and consent, the principle of minimum sufficient use, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. . At the same time, we promise that we will take appropriate security measures to protect your personal information in accordance with the industry's mature security standards.

Privacy Policy provides privacy details about how we manage the personal information that you disclose when using all of our products and services, except for specific privacy policies that are specific to our products or services. Please read and understand this Privacy Policy carefully before using our products (or services). If you have any questions, please let us know.

First.How do we collect and use all kinds of information about you (whether or not it is personal information)

        

· Information you provide to us or upload (including your contact details): We may collect any or all of the personal information you provide to us, such as your name, mobile number, email address, login account information (eg Your security-related information, name, date of birth, gender), the role permission user number you set or related messages, feedback, and any other information you provide to us.

        

· Information about adding data: When you add data to our platform, fill in the saved data information and so on.

        

· Device related information: Information related to your device when adding a device. Such as IMEI number, IMSI number, MAC address, system version, device manufacturer information, and model name

        

· We specify information about you: We may collect and use information such as your account number on our platform.

        

· Location Information (for specific services/features only): A variety of information related to your location. For example, country code, city code, mobile network code, cell identification, latitude and longitude information, and language settings.

        

· Login Information: Information related to your use of certain features, applications, and websites. Such as cookies and other anonymous identifier technologies, IP addresses, temporary message history, and standard system logs.

        

· Other information: Environmental eigenvalue (ECV) (ie from the software login account, phone device account, connected WI-FI account and geographic location information)

        

· Others' Information: When you use certain features of our products, you may be required to provide personal information about others, including nicknames, mobile numbers, and more. If you choose not to provide this type of information, some features in the product may not work properly, but it does not affect the other features in your product. By providing this information on your own initiative, you have obtained the consent of others and consent to the processing of the information about others provided by you in accordance with the purposes and methods described in this policy.

        

Second.How these personal information may be used

        

The purpose of collecting personal information is to provide you with products and/or services and to ensure that we comply with applicable laws. You hereby agree that we may process personal information for the purposes set forth in this Privacy Policy and disclose personal information to our affiliates (involving communications, social media, technology and cloud services) and third party service providers (as defined below). p>         

We may use personal information for the following purposes:

        

· Provide, process, maintain, improve, develop our products and/or services for you, and provide services through equipment or our applications.

        

· Communicate with you about your device, service, or any general query (such as updates, device firmware/software upgrades, customer advisory support, related information, notifications, etc.).

        

· Conduct marketing-related activities such as providing marketing and promotion related materials and updates. For more information on marketing and promotion related activities, please see the content entitled "Direct Marketing" shown below.

        

· Analyze and develop statistical information related to the use of our products and services to better improve our products and services.

        

· Store and maintain information about you that we use to conduct business or fulfill legal obligations.

        

· No need to communicate with our servers to provide local services.

        

Third.How do we share your personal information

        

We do not share your personal information with any other company, organization or individual, except in the following cases:

        

· Share with explicit consent: We will share your personal information with others after obtaining your explicit consent.

        

· We may share your personal information in accordance with laws and regulations or as mandatory by government authorities.

        

· Sharing with Authorized Partners: Certain of our services will be provided by authorized partners for the purposes stated in this Privacy Policy. We may share some of your necessary personal information with our partners to provide better customer service and user experience. In such cases, the data used is subject to the purposes stated in this Privacy Policy. We will only share your personal information for legitimate, legitimate, necessary, specific, and specific purposes, and will only share the personal information necessary to provide the service.

        

Fourth.How do we protect your personal information

        

· We have used industry-standard security measures to protect the personal information you provide against unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonable and practicable steps to protect your personal information. We use encryption to ensure data confidentiality; we use trusted protection mechanisms to protect against malicious attacks; we deploy access control mechanisms to ensure that only authorized personnel have access to personal information; and we hold security and privacy Protect training courses and enhance employees' awareness of the importance of protecting personal information.

        

· We will take all reasonable and practicable steps to ensure that no personal information is collected. We will only retain your personal information for the period of time required to achieve the purposes stated in this policy, unless the retention period is extended or permitted by law.

        

· The Internet is not an absolutely secure environment, and email, instant messaging, and other forms of communication with our users are not encrypted, and we strongly recommend that you do not send personal information in this manner. Please use complex passwords to help us keep your account secure.

        

· The Internet environment is not 100% secure and we will do our best to ensure or guarantee the security of any information you send us. If our physical, technical, or administrative protective equipment is destroyed, resulting in unauthorized access, public disclosure, alteration, or destruction of information, resulting in damage to your legal rights, we will bear the corresponding legal responsibility.

        

· After unfortunate personal information security incidents, we will promptly inform you according to the requirements of laws and regulations: the basic situation and possible impact of security incidents, the disposal measures we have taken or will take, you can prevent yourself And suggestions for risk reduction, remedies for you, etc. We will promptly inform you of the relevant circumstances of the incident by mail, letter, telephone, push notification, etc. When it is difficult to inform the individual information subject one by one, we will issue a notice in a reasonable and effective manner. At the same time, we will also report the disposal of personal information security incidents in accordance with the requirements of the regulatory authorities.

        

Fifth.Your rights

        

According to China's relevant laws, regulations, standards, and other countries and regions, we protect your right to access, modify, eliminate or limit your personal information:

        

· You have the right to request access to and/or correction of any personal information we hold about you. When you update your personal information, you will be asked to verify your identity before we process your request. Once we have sufficient information to process your request to access or correct your personal information, we will respond to your request within the time specified in the applicable Data Protection Act.

        

· Based on your request, we may provide you with a copy of your personal data collected and processed free of charge. For any additional requests for the same information, we may charge a reasonable fee based on actual administrative expenses in accordance with the law of use.

        

· You have the right to ask us to remove your personal information. We will consider the rationality of this elimination requirement and take reasonable steps including technical measures.

        

· You have the right to restrict our processing of your personal information, we will consider the reasonableness of this restriction to process your personal information and notify you before the restriction is lifted.

        

· You may opt out of collecting, using and/or disclosing your personal information that we hold or control by contacting us by submitting a request by e-mail to us. We will process your request within a reasonable time after you have made your request, and will not collect, use and/or disclose your personal information thereafter, based on your request.

        

Please note that your withdrawal of consent will result in certain legal consequences. By disclosing your consent to let us process the scope of your personal information, this may mean that you are not entitled to our products and services.

        

We will not charge you in principle for your reasonable request, but we will charge a fee for the repeated requests that exceed reasonable limits. For those who are unreasonably repetitive, need too much technical means (for example, need to develop new systems or fundamentally change existing practices), pose risks to the legal rights of others, or are very impractical (for example, involving information stored on backup tapes) Request, we may refuse.

        

In the following cases, we will not be able to respond to your request in accordance with legal and regulatory requirements:

        

· related to national security and national defense security;

        

· related to public safety, public health, and major public interest;

        

· related to criminal investigation, prosecution and trial;

        

· There is sufficient evidence that you have subjective malice or abuse of rights;

        

· Responding to your request will result in serious damage to the legitimate rights of you or other individuals or organizations.

        

Sixth.How do we deal with children's personal information

        

Our products, websites and services are primarily for adults. Children may not create their own user accounts without the consent of their parents or guardians.

        

For the collection of children's personal information with parental consent, we will only use or publicly disclose this information if it is permitted by law, with the explicit consent of the parent or guardian or the protection of the child.

        

If we find that we have collected personal information about a child without prior verifiable parental consent, we will try to delete the data as soon as possible.

        

Seventh.How your personal information is transferred globally

        

In principle, the personal information we collect and generate within the territory of the People's Republic of China will be stored in the territory of the People's Republic of China.

        

Because we provide products or services through resources and servers around the world, this means that your personal information may be transferred to the foreign jurisdiction of the country in which you use the product or service after obtaining your authorization. District, or access from these jurisdictions.

        

This jurisdiction may have different data protection laws or even relevant laws. In such cases, we will ensure that your personal information is adequately protected within the territory of the People's Republic of China. For example, we will ask you for permission to transfer personal information across borders or to implement security measures such as data de-identification before cross-border data transfers.

        

Eighth.How to update this privacy policy

        

We may make adjustments or changes to this Privacy Policy in due course. Any updates to this Privacy Policy will be posted on our website in the form of an updated time, except as otherwise required by laws, regulations or regulatory requirements. The content of the adjustment or change shall take effect after 7 days after notification or publication. If you continue to use any of our services or visit our related websites after the privacy policy has been adjusted or changed, we believe that this means that you have fully read, understood and accepted the revised Privacy Policy and are bound by it.

        

Ninth.how to contact us

        

If you have any questions, comments or suggestions about this Privacy Policy, please contact us by mentioning the Privacy Policy:

        

TownSteel Inc.

        

17901 Railroad Street, City of Industry, CA 91746

        

E-mail: service@townsteel.com