Date of last update :【2023-03-16】

Effective date: [2023-03-16]

This Privacy Policy (hereinafter referred to as "this Policy") applies to ZILLION DATA TECHNOLOGY CO., LIMITED (hereinafter referred to as " eSigner " or "we") official website and / or use of eSigner products or services, eSigner registration address: Rm 1406A 14/ F THE BELGIAN BANK BLDG 721-725 NATHAN RD Mongkok Hong Kong .

This policy will help you understand the following :

1.        How we collect and use your personal information

2.        How do we use cookies and similar technologies

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

4.        How do we protect your personal information

5.        Your rights

6.        How do we handle children's personal information

7.        How your personal information is transferred globally

8.        How to update this policy

9.        Infringement Complaints and Reporting Channels

ZILLION DATA TECHNOLOGY CO., LIMITED ( hereinafter referred to as "we" ) attaches great importance to the protection of your personal privacy, and we will collect, use, share and protect your personal information in accordance with this privacy policy ( hereinafter referred to as "this policy" ) .

We collect, use, share and protect your personal information for the purpose of providing you with eSigner products and services, continuously improving the quality of products and services, and protecting your account security under the premise of complying with national laws and regulations .

Please read and understand this Privacy Policy carefully before using our products ( or services ) .

1. How we collect and use your personal information

We will collect and use your personal information for the following purposes described in this policy :

(1) The usage scenarios listed are as follows:

1.        Registration

When you register eSigner APP , we need you to provide your real name, common mobile phone number or email address , and create a login password and signing password . In the link where SMS verification code is required, it may be necessary to read the verification code SMS content to assist you in filling in the verification code. If you only need to use basic browsing services, you do not need to register as our member and provide the above information.

2.        Login

When you log in to the eSigner APP , we need you to enter your mobile phone number or email address as your login account.When you log in with an enterprise account, we will need to authorize SMS and verify the validity of the enterprise account by reading the authorization code of the SMS.

3.        Real-name authentication

When you perform real-name authentication, we will also collect your ID card / passport identity certificate or facial biometric information ; mobile phone number, identity certificate or biometric information, these information are sensitive information, and the purpose of collecting such information is to comply with relevant laws and regulations real-name system requirements. In addition, in order to provide you with better services, we may use the mobile phone number you provided for telephone return visits . The triggering situations of telephone return visits are as follows: ( 1 ) Your real-name authentication has been rejected many times, and we may call you to guide you You submit correct information; ( 2 ) When the system detects that your operation is abnormal, we may actively contact you to troubleshoot the abnormal situation; ( 3 ) When you are not satisfied with eSigner 's consultation reply, we may call you to contact you Solve your problem.

If you do not provide such information, you will not be able to use eSigner's membership services such as initiating contracts, applying for notarization, and enjoying eSigner 's membership services, but it will not affect the basic browsing functions of using eSigner products or services.

4.        Signature

When you set up a signature, we will apply for the photo album permission to obtain your signature picture as the personal signature style displayed after the contract is signed, so that you can sign the contract conveniently. You can request to change, delete this picture.

5.        Security (fingerprint, face ID )

When you use the APP , you can set fingerprint and face ID to log in. We will obtain your fingerprint information / face ID for login verification. You can also choose a password or a verification code to log in without setting.

6.        Send the contract

When you use the app to send a contract, we will apply for your storage permission to view local files; may apply for camera / album permission to upload contract documents; apply for address book permission to fill in the contact information of the mobile phone , so that your contract can be issued.

7.        Sign and approve

When you sign for approval, we will use the signature image you have set as your personal signature style and display it in the corresponding position of the contract document. You can change, delete this picture. But after deletion, it cannot be signed.

8.        Search

When you search, we may apply to read the data in your clipboard to search for the name of the contract file, so that you can find the contract file you need.

9.        Scan

When you use the scan function, scan the QR code to view it, and sign the contract, we will apply for your camera permission .

10.     Question feedback (suggestion and consultation)

When you give us feedback in "My - Suggestions and Consultations", you may be required to provide your contact email address and phone number so that we can reply to you in a timely manner. When you call our customer service hotline, we may apply for phone permission from you so that you can call customer service with one click.

11.     Supplementary contract attachment

After signing the contract, when supplementing the contract attachments, you can choose to supplement the content of photos, documents, and transaction SMS certificates. Depending on the type of supplement, you need to authorize the corresponding storage photo 、SMS permissions.

(2) To provide you with products or services

When you use eSigner service, in order to ensure your normal use of our service, we will collect your device name (including alias), device model, operating system, IP address, MAC address, device software version information, device identification code, device Identification codes, device identifiers, fingerprint information, face ID information, information location, network usage habits, and other log information related to eSigner services . This type of information is the basic information that must be collected to provide services. If you do not agree to our recording The aforementioned information may not be able to complete the risk control verification.

Please note that individual device information and log information cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, during the combined use, such non-personal information will be regarded as personal information, unless authorized by you Or unless otherwise stipulated by laws and regulations, we will anonymize and de-identify such personal information.

1.        Camera permission and photo album permission: When you use functions such as scanning, avatar picture setting, screenshot feedback, etc., you need to enable camera permission and / or photo album permission (subject to the specific function you use), so that you can conduct real-time Take pictures or upload pictures / videos. If you choose not to enable the corresponding permissions, you will not be able to use specific functions related to real-time shooting or image / video uploading, but this will not affect your other services provided by the eSigner APP .

2.        Functions based on face, fingerprint and other biometric identification: When you log in or sign with your face or fingerprint ID , you need to authorize the device's face and fingerprint ID verification function to help you complete personal identification, login, verification and Sign command operations. When you verify your face, fingerprint ID , etc., we only collect the verification results, not your biometric information;

When you contact us, we may save your communication / call records and content or the contact information you left , so as to contact you or help you solve problems, or record the solutions and results of related problems.

In order to ensure your normal use of our services, we will also apply for storage permissions to save your contract documents;

Apply for permission to open the phone, get the status of the phone, so as to facilitate one-click call to customer service;

Apply for permission to open the camera to take photos of documents and seals;

Apply to open the address book permission to obtain contact information , so as to facilitate filling in the contract sender;

Apply for location permission to obtain location information , so as to obtain more accurate identity verification information and complete identity verification and risk control.

To sum up, the list of personal information we collect and its purpose / necessity, scope and method are as follows:

(3) To provide you with security protection

Please note that in order to ensure the authenticity of membership and provide you with better security, you can provide us with your ID card, passport, and other identifiable identity information, as well as facial feature biometric information to complete real-name authentication. If you refuse to provide the above information, you may not be able to use the service of initiating contracts and applying for notarization, but it will not affect your use of browsing services.

(4) Other purposes

When we use information for other purposes not specified in this policy, or use information collected for specific purposes for other purposes, we will ask for your prior consent.

(5) Exceptions to Authorization and Consent

According to relevant laws and regulations, the collection of your personal information in the following situations does not require your authorization and consent :

1.        Related to national security and national defense security ;

2.        Related to public security, public health, and major public interests ;

3.        Related to criminal investigation, prosecution, trial and execution of judgments ;

4.        In order to protect the life and property of the personal information subject or other individuals, but it is difficult to obtain your own consent ;

5.        The collected personal information is disclosed to the public by you ;

6.        Collecting personal information from legally disclosed information, such as legal news reports and government information disclosure channels ;

7.        Necessary to sign a contract according to your request ;

8.        It is necessary to maintain the safe and stable operation of the products or services provided ;

9.        Other circumstances stipulated by laws and regulations.

If we stop operating eSigner products or services, we will stop collecting your personal information in a timely manner, notify you of the cessation of operation in the form of notification or announcement one by one, and delete or anonymize the personal information we hold.

2. How do we use cookies and similar technologies

In order to ensure the normal operation of the website and provide you with an easier access experience, we will store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names and some numbers and characters. We do not store personally identifiable or privacy-related information in cookies .

You can manage or delete Cookie according to your own preference . See AboutCookies.org for details . You can clear all cookies saved on your computer , and most web browsers have the function of blocking cookies . But if you do this, you will need to change your user settings every time you visit our website. For more information on how to change your browser settings, please visit the relevant settings page for your browser.

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

(1) Sharing

We will not share your personal information with companies, organizations and individuals other than eSigner service providers, except in the following cases :

1.        Sharing with explicit consent : After obtaining your explicit consent, we will share your personal information with other parties.

2.        Sharing under statutory circumstances : We may share your personal information externally in accordance with laws and regulations, or in accordance with the mandatory requirements of administrative and judicial authorities.

3.        Sharing with authorized partners : Only to achieve the purpose stated in this privacy policy, some of our services will be jointly provided by us and authorized partners. We will share some of your personal information with our partners in accordance with laws and regulations. Your personally identifiable information will be transmitted to an electronic certification service agency (CA, Certificate Authority) or personally identifiable information and signed contract information will be transmitted to a notary office, which will be used by the CA for the purpose of issuing digital certificates or by the notary office for the purpose of issuing notarized documents. save. We will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share personal information necessary to provide services. Our partners have no right to use the shared personal information for other purposes unrelated to products or services.

4.        Sharing with third parties through SDK : Some products or services may be provided by third parties or jointly provided by us and third parties, so only by sharing your information can we provide the products or services you need. The eSigner APP and electronic contract cloud platform provide you with products or services by embedding plug-ins (such as SDK ), and in the process, third-party service providers may collect, use and store your relevant data or information.

The details of personal information collected by third-party SDK/APP are as follows:

1.        Tencent Cloud facial recognition SDK

Name of the third party: Tencent Cloud Computing ( Beijing ) Co., Ltd.

Purpose of use: to identify the user's identity and complete identity verification in order to comply with the provisions of national laws and regulations and provide services

Necessity: for user identity verification

Processing method: Secure processing through de-identification and encrypted transmission. Among them, the device fingerprint information will be specially de-identified

Types of personal information: the name, ID card information and its image, bank card information and its image, image and video data information generated during the identity verification process provided by the user when registering and using the service; and related operations and behaviors of this service Information (operation records, device model, IP address, androidID , MAC address information, location information, device fingerprint). Among them, the list of device fingerprints is detailed below

Third-party privacy policy: Secure processing through de-identification and encrypted transmission. Among them, the device fingerprint information will be specially de-identified

Tencent Cloud Face and Body SDK Personal Information Processing Authorization Letter

https://miniprogram-kyc.tencentcloudapi.com/s/h5/protocolTencent.html

Tencent Cloud Privacy Protection Statement

https://cloud.tencent.com/document/product/301/11470

2.        Android QR code generation and scanning tool ( ZXing )

Third Party Name: GoogleInc

Purpose of use: scan the QR code to log in to the web or sign a contract

Necessity: for better user experience, quick login and sign

Processing method: secure processing through de-identification and encrypted transmission

Access permission type: Allow the app to use the camera to take photos and record videos at any time, allow the app to modify or delete the contents of the memory card, allow the program to access the network, may generate GPRS traffic, allow the app to control the vibrator, allow the app to use the flash

Third Party Privacy Policy:

https://github.com/zxing/zxing

3.        Tencent BuglySDK

Name of the third party: Shenzhen Tencent Computer System Co., Ltd.

Purpose of use: capture app crash information

Necessity: Easy to troubleshoot and solve problems, improve app performance and stability, so as to ensure your safe use and enjoy better services

Processing method: safe processing methods such as de-identification and encrypted transmission

Obtain user information: log information (software version, user ID, user-triggered events, system error information, time stamp, application identifier, application version, application distribution channel, open independent device identifier ( Open UDID ), iOS advertising Identifier ( IDFA) , network card ( MAC ) address, International Mobile Equipment Identity ( IMEI ), device model, terminal manufacturer, terminal device operating system version, session start / stop time, language location, time zone and network status)

Third Party Privacy Policy:

https://cloud.tencent.com/document/product/301/11470

4.        ReactNative development framework

Third Party Name: FaceBookInc

Purpose of use: Google's mobile UI framework, which can quickly build high-quality native user interfaces on iOS and Android

Necessity: Used to develop the interface display and functions of the app , copy the contract link to the clipboard

Processing method: safe processing methods such as de-identification and encrypted transmission

Access permission type: set clipboard data, modify setting items in the settings application, allow applications to access the device's mobile phone functions, allow applications to read files in the device's external storage space (built-in SDcard and external SDCard ), allow programs to access Network, which may generate GPRS traffic, allows applications to view and obtain network information status , such as whether the current network connection is valid

Third Party Privacy Policy:

Facebook ReactNative Privacy Policy Statement

https://www.google.com/intl/zh/policies/privacy/

Note: The Flutter development framework includes:

io.flutter.embedding

io.flutter.plugins

DidWebViewFlutter

io.flutter.view

io.flutter.util

com.bestsign.bestsign_flutter

5.        com.stub.StubApp(360SDK)

Name of the third party: Beijing Qihoo Technology Co., Ltd.

Purpose of use: to strengthen the Android apk installation package

Necessity: anti-reversal, anti-tampering, data protection, anti-malware

Processing method: secure processing through encrypted transmission

Access permission type: allow applications to access the device's phone functions, allow applications to modify or delete content in the memory card, allow applications to read files in the device's external storage space (built-in SDcard and external SDCard ), allow programs to access the network, possibly Generate GPRS traffic, allow the application to view the status of obtaining network information, such as whether the current network connection is valid, modify the setting items in the setting application, and allow the application to access the mobile phone function of the device

Third Party Privacy Policy:

360 Reinforced Security Privacy Policy

https://jiagu.360.cn/#/global/help/295

6.        AndroidSupportLibraryFragment & AndroidSupportLibraryCompat

Third Party Name: GoogleInc

Purpose of use: development framework

Necessity: anti-reversal, anti-tampering, data protection, anti-malware

Processing method: secure processing through encrypted transmission

Access permission type: Allow the application to modify or delete the content in the memory card, modify the setting items in the settings application

Third Party Privacy Policy:

Google Android Framework Privacy Agreement

https://www.google.com/intl/zh/policies/privacy/

7.        Alipay app

Name of the third party: Ant Technology Group Co., Ltd.

Purpose of use: to identify the user's identity and complete the identity verification, so as to comply with the relevant requirements of national laws and regulations

Necessity: for user identity verification

Processing method: When the user registers and uses the service, the encrypted transmission is processed safely

Personal information type: the name, ID card information and its image provided by the user when registering and using the service, as well as the video data information generated during the verification process

Third Party Privacy Policy:

https://render.alipay.com/p/c/k2cx0tg8

8.        Zhuoxin ID

Name of the third party: China Academy of Information and Communications Technology

Purpose of use: To provide equipment identification and security risk control services

Necessity: Used for user identity verification security risk control services

Processing method: secure processing through encrypted transmission

Types of personal information: device information, device network information, device environment information, device application information

Third Party Privacy Policy:

https://zxid.caict.ac.cn/privacy

The Tencent Cloud facial recognition SDK includes: WbCloudFaceLiveSdk , WbCloudOcrSdk , WbCloudNormal , com.webank.mbank , com.tencent.youtulivecheck , 4 SDK components. Among them, the description of Tencent Cloud SDK 's identity collection permission for face verification:

Device Fingerprint Checklist:

Among them, the description of io.flutter.embedding and io.flutter.plugins permissions:

The above information can only be obtained after obtaining the consent of the user.

Through the relevant agreements signed with the above-mentioned third-party service providers, eSigner -related specifications and reasonable product process design, eSigner strictly requires that any data obtained by you should abide by relevant laws and regulations, and must obtain your data in advance. Explicitly agree to take necessary data protection measures (such as anonymizing and de-identifying such personal information), and only use your relevant data reasonably for the purpose of products or services, and provide you with the right to modify or delete your own data. method, and all data must be deleted when the service is stopped, so as to protect your data and privacy from infringement as much as possible. Before accepting or using third-party products or services, you should fully understand the terms and policies of third-party products or services. If you find that any third-party service provider has violated relevant laws and regulations, you can complain to eSigner , and eSigner will issue a complaint after verification deal with.

(2) Transfer

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

1.        Transfer with explicit consent : After obtaining your explicit consent, we will transfer your personal information to other parties ;

2.        In the event of a merger, acquisition or bankruptcy liquidation of an eSigner service provider, or other situations involving mergers, acquisitions or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization that holds your personal information to continue Be bound by this policy, otherwise we will require the company, organization and individual to ask you for authorization again.

(3) Public disclosure

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

1.        With your explicit consent or based on your active choice, we may publicly disclose your personal information ;

2.        We may publicly disclose your personal information under the circumstances of laws, legal procedures, lawsuits or mandatory requirements of government authorities. We will notify you in a timely manner if the law enforcement agency requests disclosure, unless the law enforcement agency otherwise prohibits disclosure.

(4) Exceptions to obtaining prior authorization and consent when sharing, transferring, and publicly disclosing personal information

In the following situations, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent :

1.        Related to national security and national defense security ;

2.        Related to public security, public health, and major public interests ;

3.        Related to criminal investigation, prosecution, trial and execution of judgments ;

4.        Personal information that you disclose to the public by yourself ;

5.        Collecting personal information from legally disclosed information, such as legal news reports and government information disclosure channels. According to the law, sharing and transferring personal information that has been de-identified and ensuring that the data recipient cannot restore and re-identify the subject of personal information is not an act of external sharing, transfer and public disclosure of personal information. Storage and processing will not require further notice to you and your consent.

(5) Provide proof

For legal documents such as data messages signed through the eSigner platform, eSigner has the right to send the signing information of the aforementioned legal documents, such as the name of the party, the number of the unified social credit code certificate (or organization code certificate), ID number, digital certificate The number, IP address, signing time, etc. are disclosed to the contracting party of the data message as evidence of the signing of the legal document.

(6) The storage period of your personal information and how to deal with the overdue period

Article 24 of the "Electronic Signature Law" stipulates that "the electronic certification service provider shall properly store the information related to the certification, and the information storage period shall be at least five years after the electronic signature certification certificate expires. Therefore, your personal information can be used for free on eSigner If it has been stored for five years, if you have not processed it or paid any fees for more than five years, we have the right to delete it and will not assume any legal responsibility.

4. How do we protect your personal information

(1) We have adopted industry-standard security protection measures to protect the security of the personal information you provide to prevent unauthorized access, public disclosure, use, modification, damage or loss of personal information. When exchanging data between your browser and the server, it is protected by SSL (Secure Socket Layer) protocol encryption ; we also provide HTTPS (Hyper Text Transfer Protocol over Secure Socket Layer) protocol secure browsing mode for the eSigner website ; we will use encryption technology Improve the security of personal information ; we will use trusted protection mechanisms to prevent malicious attacks on personal information ; we will deploy access control mechanisms to ensure that only authorized personnel can access personal information ; we will hold security and privacy protection training courses, Strengthen employees' awareness of the importance of protecting personal information.

(2) We have obtained the following certifications : Information System Security Level Protection Level 3 Certification, ISO/IEC 27001 Information Security Management System Certification, ISO27018 Public Cloud PII Protection Management System Certification, ISO38505-1 Data Governance Certification, Trusted Cloud Certification and ISO22301 Business continuity management system certification.

(3) We will take reasonable and feasible measures 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 an extended retention period is required or permitted by law.

(4) The Internet is not an absolutely safe environment, and we strongly recommend that you do not use communication methods not recommended by eSigner to send personal information. Please properly protect your personal information and only provide it to others when necessary. If you find that your personal information, especially your account or password, has been leaked, please contact eSigner customer service immediately so that we can take corresponding measures according to your application.

Please use a complex password to help us ensure the security of your account. We will do our best to keep any information you send us secure. If our physical, technical or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering or destruction of information, resulting in damage to your legitimate rights and interests, we will bear corresponding legal responsibilities.

(5) After an unfortunate personal information security incident occurs, we will promptly inform you in accordance with the requirements of laws and regulations : the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with it, and you can prevent and reduce it on your own. Risk advice, your remedies. We will inform you of the event-related situation by email, letter, phone call or push notification. When it is difficult to inform the personal information subject one by one, we will issue an announcement in a reasonable and effective manner. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

(6) By submitting personal information through the eSigner platform, you agree and authorize eSigner to collect, use, share and protect your personal information. If you apply for withdrawal of authorization due to special reasons, please contact us in time so that we can deal with it accordingly .

5. Your rights

You can access and manage your personal information in the following ways :

(1) Access to your personal information

You have the right to access your personal information, except for exceptions provided by laws and regulations. You can access your personal information yourself by :

Account information——If you want to access or edit basic personal information in your account, change your password, and add security information, you can perform such operations through the "User Center" by logging in to your account.

If you cannot access the personal information through the above path, you can contact us through eSigner customer service at any time. We will respond to your access request within 10 working days.

For other personal information generated during your use of our products or services, we will provide you with the relevant arrangements in " ( 6 ) Responding to your above request" in this article.

(2) Correct or supplement your personal information

When you find that the personal information we process about you is wrong, you have the right to ask us to make corrections or additions. You can submit a correction or supplementary application through the methods listed in "(1) Access to your personal information".

(3) Delete your personal information

You can delete some of your personal information through the methods listed in "(1) Access to your personal information".

You can request us to delete your personal information under the following circumstances :

1.        If our handling of personal information violates laws and regulations ;

2.        If we collect and use your personal information without your explicit consent ;

3.        If our handling of personal information violates our agreement with you ;

4.        If you no longer use our products or services, or you voluntarily log out of your account ;

5.        If we no longer provide you with products or services.

If we decide to respond to your deletion request, we will also notify the subjects who have obtained your personal information from us and request them to delete them in a timely manner, unless otherwise stipulated by laws and regulations, or these subjects have obtained your independent authorization.

When you delete information from our service, we may not delete the corresponding information from the backup system immediately, but we will delete the information when the backup is updated.

(4) Cancellation of account

When you need to terminate the use of eSigner products or services, you can log in to the eSigner APP , enter [My - Personal Information] and click the [Account Cancellation] button to apply for cancellation of the eSigner account. If you are not convenient for the above operations, you can also manually apply for canceling your eSigner account through our official customer service phone (see Article 9 of this policy) .

After you voluntarily cancel your account, we will stop providing you with products or services, and delete or anonymize your personal information in accordance with the applicable provisions of the Civil Code of the People's Republic of China or the Electronic Signature Law of the People's Republic of China.

(5) Withdrawal of consented authorization

When you need to withdraw the system's authorization of eSigner , you can enter the mobile phone system settings to cancel the system authorization of eSigner .

(6) Automatic decision-making of constraint information system

In some business functions, we may only make decisions based on non-manual automatic decision-making mechanisms including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will also provide appeal methods on the premise of not infringing on eSigner's trade secrets or other user rights and social public interests.

(7) Respond to your above request

For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

In the following situations, we will not be able to respond to your request in accordance with laws and regulations :

1.        Related to national security and national defense security ;

2.        Related to public security, public health, and major public interests ;

3.        Related to criminal investigation, prosecution, trial and execution of judgments ;

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

5.        Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations ;

6.        Those involving commercial secrets.

(8) Respond to your above request

When you and the contracting party of the data message sign legal documents such as the data message, you should judge whether you and other parties are qualified as subjects. If you and / or other parties are persons without or with limited capacity for civil conduct, you are not allowed to sign or can only sign legal documents that are suitable for your own age, intelligence and mental health. If the legal documents such as data messages signed through the eSigner platform are invalid due to the unqualified subject , the responsibility and legal consequences shall be borne by you and other parties to the legal documents.

6. How do we handle children's personal information

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

For the collection of children's personal information with parental consent, we will only use or publicly disclose this information when permitted by law, with the explicit consent of parents or guardians, or when it is necessary to protect children.

Although local laws and customs define children differently, we consider anyone under the age of 14 to be a child. If we discover that we have collected personal information from children without prior verifiable parental consent, we will try to delete the data as soon as possible.

7. How your personal information is transferred globally

The personal information we collect and generate during our operations in the People's Republic of China will be stored in China, except for the following circumstances :

1.        There are clear provisions in laws and regulations ;

2.        Obtain your explicit authorization.

In view of the above situations, we will ensure that your personal information is provided with sufficient and equal protection within the territory of the People's Republic of China in accordance with this Privacy Policy.

8. How to update this policy

Our Privacy Policy is subject to change.

We will not limit your rights under this Privacy Policy without your express consent.

For major changes, we will also provide more prominent notices ( including notices that we will post on the eSigner website ) .

Update of this policy on the APP : After each content update, we will display a red dot prompt in [My - About eSigner - Privacy Policy] through the APP to remind you to read it, and after obtaining your consent, we will then To provide you with services.

Major changes referred to in this policy include, but are not limited to :

1.        Major changes have taken place in our service model. Such as the purpose of processing personal information, the type of personal information processed, and the way the personal information is used ;

2.        We have a significant change in control. Such as changes in owners caused by mergers and acquisitions ;

3.        The main object of personal information sharing, transfer or public disclosure changes ;

4.        There are major changes in your right to participate in the processing of personal information and how to exercise it ;

5.        When there are changes in our responsible department, contact information and complaint channels responsible for handling personal information security ;

6.        When the personal information security impact assessment report indicates that there is a high risk.

We will also archive previous versions of this Policy for your review. If you continue to use the eSigner service after this policy is revised , it means that you have fully read, understood and accepted the revised policy and are willing to be bound by the revised policy.

9. Infringement Complaints and Reporting Channels:

If you have any questions, comments or suggestions about this Privacy Policy, especially regarding the protection of personal information, you can contact us in the following ways:

1.        Complaint and report telephone: 400-993-66659

2.        E- mail for complaints and reports: support@esigner8.com

Generally, we will reply within fifteen days.