Privacy Policy

I. Introduction

1.1 This privacy policy explains how Shenzhen Maxtop Smart Tech. Co., Ltd.and its affiliates (hereinafter referred to as "MAXTOP") which how to collect, use, share, transfer, publicly disclose and protect users (hereinafter referred to as "you") ) personal information and the corresponding rights which enjoyed by users. The personal information involved in this privacy policy refers to various information that can be individually or combined with other information to identify a specific individual by electronic or other means, including but not limited to basic personal information (for example: natural person’s name, date of birth, ID number, address, phone number, etc.), personal device information (for example: device model, unique device identification code, etc.), address book, personal biometric information, personal location information, transaction information, etc. For the handling of personal information involved in this privacy policy, MAXTOP is the personal information controller.

1.2 This privacy policy is only applicable to scenarios which display this privacy policy or the link to this privacy policy such as MAXTOP website, products and services. If this privacy policy does not cover certain scenarios of specific personal information, we will clarify to you in the form of supplementary policies or pop-up windows. In special circumstances that comply with the law, you have the right to refuse our processing of your personal information at any time.

When you use our products or services, it means that you fully understand and agree to the entire content of this privacy policy. If you are under the age of 18, please read and fully understand this privacy policy accompanied by your guardian, and obtain the consent of the guardian to use our services or provide us with information. Please read carefully and choose to accept this privacy policy or not. The terms and conditions of your personal information rights and other important contents have been indicated in bold. Please pay special attention to it.

2. Types of personal information collected by MAXTOP

We may ask you to provide personal information in any scenario you interact with us. If you do not provide relevant information, you may not be able to achieve the specific purpose of a specific scenario, for example, you cannot purchase MAXTOP products, our call center cannot contact you and provide you with pre-sales and after-sales services, and you cannot download updated systems and applications. The following is an introduction to the types of personal information we may collect and collection scenarios:

2.1 Personal information you provide when you use our services or equipment:

2.1.1 The basic information and transaction information you provide to MAXTOP when you register for an account and purchase MAXTOP products, including: user name, phone number, email, mailing address, zip code, consignee information, and payment method;

2.1.2 The personal information you provide when using our customer service and after-sales service: When you call our service call center for help, we may ask you to provide your name, phone number, product information, delivery time, and record the number of calls of yours, the date of the call, the problems encountered and the solutions we give you to provide you with our help or after-sales service;

2.1.3 The personal information you provide when you participate in our online and offline activities (including but not limited to marketing activities, user research activities, etc.), including your name, gender, email address, mobile phone number, and your personal photos which uploaded during our events. When you participate in some offline activities, we also need your ID information in order to book your accommodation and transportation.

2.1.4 The information you provide through the MAXTOP community, such as the knowledge and experience you share through forums and friends.

2.2 The personal information we obtained from you when you activate and use MAXTOP devices (for example: watches, bracelets, smart accessories, etc.) or MAXTOP software services:

2.2.1 Device information: including device name and model, device identification code (such as IMEI and SN), operating system version number; this type of information is the basic information that must be collected to provide you with services, and is used to ensure network and operational security and the normal and safe operation of equipment functions;

2.2.2 Software information: including the version number of the software and serious error log of system;

2.2.3 Network information: including the browser type, version, language, OS version, resolution, website operation elements, your network IP address and web browsing information that you use to log in to MAXTOP mall, and other user behavior information which obtained through cookies and other similar technologies including the number of searches and clicks on the products and active windows you browse, also the length of time spent on the page.

2.2.4 Location information:

(1) The country information displayed by the telecommunications operator code you use; some pre-installed applications based on location-based services will collect your location information with your consent (some applications will obtain location information), these pre-installed applications Including map, navigation and weather service applications. This kind of pre-installed application requires you to authorize us to use your location permission when collecting your location information, and providing you with related services.

(2) The information provided by you or other users during the use of the device or service may include your geographic location information, such as the location information of your region contained in the account information you provide.

2.2.5 Information we collect in other business scenarios:

(1) When you use the voice recognition function we provided, we will collect your voiceprint information and perform pointing operations. At this time, we need you to authorize us to use your microphone permissions;

(2) When you submit suggestions and feedback through the MAXTOP community, we will obtain your device identification code for security purposes;

(3) We may also obtain your information through other legal channels. We can combine this information with your known information before you understand and agree that . This will help us to update, expand and analyze our records, identify new customers, and provide you with products or services that you may interested

(4) If you provide us with personal information about others, or other people provide us with information about you, we will only use that information for the specific purpose for which the information is provided.

2.3 Information obtained from the third parties:

2.3.1 Where permitted by law, we obtain information from the third-party channels or partners. For example, when you use the third-party online account to register your MAXTOP account or log on to our website, MAXTOP may extract your account information from the third-party network service company. According to the third party network account you choose, we may collect your WeChat account, QQ number, Alipay account, MicroBlog account information, and only account information.

2.3.2 Your information contained in the information posted and shared by other users, for example, the photos posted by other users in the MAXTOP community may contain your information.

2.3.3 Except as otherwise provided by laws and regulations, in the case of obtaining information from the third party, we will ask the personal information provider to indicate the source of the personal information, also confirm the legality of the source of the personal information, and use the information only within the authorized scope of the information.

2.4 Collection and use of non identifying information:

Non identifying information refers to the information that can not be directly connected with any specific individual, this part of information is not personal information. In order to improve the quality of products and services and better meet the needs of users, we will collect non identifying information, including the statistical information of application download, installation, start using and uninstall; usage statistics of system functions.

3. How MAXTOP uses your personal information

MAXTOP uses your personal information for the following purposes, one or more of which may apply at the same time. If we use your personal information for purposes other than the following or to the extent permitted by law, we will obtain your consent again based on special purpose needs.

3.1 For authentication, security, fraud monitoring, archiving and backup purposes, to ensure the security of products and services that the MAXTOP provides to you. At the same time, MAXTOP shall fulfill the legal obligations under the relevant laws of network security and personal information protection to ensure that personal information protection reaches the level of security. 

3.2 Provide services to you, such as order processing, receiving and sending goods, refund of payment, use of equipment, realization of product functions, after-sales repairing, implementation of electronic guarantee plan, push system upgrade information, etc; we may disclose your personal information to the third-party partners and service providers in order to provide you with products or services. For example, the membership rights and after-sales service software platform needs to use MAXTOP account to directly log in to the cooperative the third-party service provider platform for service operation with your authorization and consent; If you do not agree to the authorization, we will not share your personal information with such the third-party cooperative service providers.

3.3 Contact with you: in the process of providing products and services to you, we may contact you directly according to the contact information you provide to us. For example, if we find that you have posted content on the MAXTOP website, indicating that you have complaints about MAXTOP products or services, or need technical assistance from MAXTOP, we will contact you according to the way you left to learn more information and help you solve problems.

3.4 Help MAXTOP improve products and services

(1) For example, MAXTOP will analyze and research the collected data, and make more humanized adjustments to the operating system and interactive interface design according to the user's use characteristics; If the user chooses to send us the details of the error, MAXTOP can modify the software according to the specific information of the error so that similar software errors will not occur again;

(2)MAXTOP may understand the regional distribution of MAXTOP watches through the receiving address and the country where the equipment is used, and adjust the distribution of after-sales service outlets, personnel and language, so as to make it easier for users to purchase MAXTOP products and experience MAXTOP services.

3.5 Promoting, sales promotion, user care and personalized pushing

MAXTOP may use the collected personal information for promoting, sales promotion, user care and personalized pushing in the service or MAXTOP device or app application function:

(1) If you agree to the Email / SMS subscription, MAXTOP may send you information about products, activities and services that we think you may be interested in, and may also send you holiday greetings; If you are not willing to receive such email, you can click "unsubscribe" at any time to unsubscribe; if you are not willing to accept such SMS, you can choose to unsubscribe according to the SMS prompt.

4. How does MAXTOP share, transfer and publicly disclose your personal information

4.1 We may disclose your personal information between affiliated companies or subsidiary companies, and ensure that users' personal information has the same level of protection between affiliated companies and subsidiary companies, we will only share your information within our affiliated companies for specific, clear and legitimate purposes, and only share information necessary to provide the services.

4.2 MAXTOP may disclose your personal information to partners under certain circumstances, including:

(1) When you buy MAXTOP products in MAXTOP online store, MAXTOP will disclose the information of the products you purchased and the information of the consignees to the logistics suppliers who have signed the cooperation agreement with us to send the products to you;

(2) If you have purchased MAXTOP's extended warranty service in some sales areas, MAXTOP may disclose your personal information to the insurance company after the repair fact appears,

(3) When you use part of the services and functions provided by MAXTOP’s partners or the third parties, with your consent, MAXTOP may disclose your personal information necessary for the realization of such services and functions to partners or the third parties for the purpose or function of the services.

4.3 When information may be transferred due to our possible merger, division, acquisition, asset sale or bankruptcy liquidation, etc, We will require the successor to protect your personal information in accordance with the laws and regulations and the standards not lower than this privacy policy, and inform you of the relevant information. If the successor changes the purpose of using the personal information, we will ask the successor to obtain your consent again.

4.4 In addition, in the case of complying with the law or performing legal procedures, MAXTOP may disclose your information to public authorities that have the right to request us to provide users' personal information. And, in the following situations, we do not need your consent to collect, use, share, transfer, and publicly disclose personal information:

(1) Related to the country and national defense security;

(2) Related to criminal investigations, public security investigations, and criminal proceedings;

(3) To maintain public safety, public health, and major public interests;

(4) To comply with applicable laws and regulations, court judgments, rulings, and regulations or requirements of relevant government agencies or statutory authorized organizations;

(5) In order to protect your or other individuals' life, property and other major legal rights and interests, but it is difficult to obtain the authorization and consent of the person;

(6) Your personal information disclosed to the public by yourself;

(7) Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

(8) We have reasonable reasons to believe that we need to comply with laws and regulations and other relevant regulations;

4.5 When sharing your personal information with third parties under any circumstances, we strive to disclose it to third parties as permitted by law, and require data recipients to process and protect your personal information in accordance with laws and regulations.

4.6 MAXTOP promises not to sell personal information to any third party, and guarantees the legal and reasonable use of personal information within the scope permitted by law.

5. How do you access and control your personal information

5.1 MAXTOP will do everything possible to adopt appropriate technical means to ensure that you can access, update, correct, delete your registration information or other personal information provided when using MAXTOP's services. When accessing, updating, correcting and deleting the aforementioned information, MAXTOP may require you to verify your identity to ensure information security. You can access, update, correct and delete the personal information you provide in the following ways, and you can also contact us in the manner described in this privacy policy. However, please be aware that the modification and deletion of personal information may affect the use of related services involved in the information or cause the service to be unavailable.

(1) You can access, update and correct your personal account information by logging in to the official website maxtop.asia;

(2) You can request to delete your personal information by contacting the call center or emailing info@maxtop.asia ;

For other personal information generated during your use of our products or services, if you want to access, correct, or update, you can contact us through the methods described in this privacy policy, and we will meet your requirements within the time limit required by law. Legal request.

In addition, in the following situations, you can also request us to delete personal information through the contact information in this privacy policy:

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

b. If we collect and use your personal information without obtaining your consent;

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

d. If you no longer use our products or services, or you cancel your MAXTOP account;

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

If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us and request them to be deleted in a timely manner, unless laws and regulations provide otherwise, or these entities obtain your independent authorization. To

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

5.2 You can choose to cancel your MAXTOP account at any time. You can log off your account in the personal account management function on the official website maxtop.asia. Before you cancel your account, we may need to verify your personal identity, security status, device information, etc. You know and understand that the act of canceling your account is irreversible. After you cancel your account, we will delete or anonymize your personal information, except as otherwise provided by laws and regulations.

5.3 Under the circumstances of meeting the law, you have the right to restrict the processing of your personal information, and you also have the right to request us to provide a machine-readable copy of your personal information that satisfies a certain structure and meets the usual standards of use.

5.4 You can control the sharing of your personal information. For example, you can turn off the sharing location button to terminate the sharing of the geographic location information of your device. You can also revoke the consent to the data collection and processing made in the previous period. Please understand that the specific The business functions and services of the company will require your information to be completed. When you withdraw or withdraw your consent or authorization, we will no longer be able to provide you with the functions and services corresponding to the withdrawal of your consent or authorization, and will no longer process your corresponding individual information. However, your decision to withdraw your consent or authorization will not affect our previous processing of personal information based on your authorization.

5.5 Many of the services we provide allow you to share your relevant information publicly. For example, your public posts in the MAXTOP community and the pictures you upload in maxtop.asia activities may be read, collected and collected by other users with access rights. use. If you wish to delete the information of these public channels, please contact us via email. In some specific circumstances, we may not be able to delete your information. In this case, we will notify you and tell you the reason why it cannot be deleted.

5.6 If you have any needs, you can contact us according to the contact information recorded in this Privacy Policy and request the realization of your rights; if we have a reasonable basis to believe that your request is fraudulent, unfulfillable, or the country and region where you are located The law does not stipulate certain personal data rights, and we will reject your request.

5.7 If you find any violation of the law regarding your personal information processing, you can lodge a complaint with a supervisory authority with jurisdiction.

6. How does MAXTOP protect your personal information

6.1 Storage time: MAXTOP will only retain your personal information for the period necessary for the purposes described in this "Privacy Policy" and within the time limit required by laws and regulations.

6.2 MAXTOP uses various management policies (such as formulating an information security system, signing a confidentiality agreement with employees who manage information, allowing only work-related employees to access the collected information, etc.), security technologies and procedures (such as accessing passwords, access control isolation , Computer use monitoring, etc.) to prevent loss of information, improper use, unauthorized reading or disclosure. For example, in some services, MAXTOP will use encryption technology (such as SSLLTLS) to protect the personal information you provide. However, please understand that due to technical limitations and various malicious methods that may exist, in the Internet industry, even if you do your best to strengthen security measures, it is impossible to always guarantee 100% information security. You need to understand that the system and communication network you use to access MAXTOP's services may have problems due to factors outside MAXTOP's controllable range.

6.3 Safety compliance certification:

MAXTOP has established an information security system that is suitable for business development by referring to domestic and foreign information security standards and best practices. At present, We have passed ISO27001 certification and PCI-DSS payment card industry data security standard certification.

6.4 If MAXTOP to knowledge capture and store the data security hazards, or due to external behavior (such as hacker attacks) users non-public information is disclosed to unrelated third parties, despite other liability provisions in this policy, MAXTOP will still take it deems appropriate and reasonable measures (including but not limited to internal investigation, report and notify law enforcement agencies, and cooperate with law enforcement agencies, work, etc.) reduce the effects of accidents for the users; At the same time, MAXTOP will also take legal and reasonable measures to inform relevant users of the disclosed information and the extent of MAXTOP's knowledge of such information when it deems appropriate.

6.5 data storage and multinational transfer: usually, we will collect and produce in the personal information stored in the territory of the People's Republic of China, as a result of business development or company management such reason need to transfer abroad, your personal information may be international (regional) transmission and transfer, and in the target country (region) for storage and handling, but we will follow the relevant state laws and regulations. According to the laws of your country or region, the receiving country or region may not meet the adequacy requirements. We promise that we will have appropriate security measures in place to ensure that the data protection level meets the adequate requirements of the laws and regulations of your country and region.

7、Protection of minors' personal information

7.1 Our products and services are mainly designed for adults, and we will not actively collect minors' personal information;Any customer who is recognized as a minor under the laws of his/her country or region shall obtain the consent of his/her parents or guardian before using our products and services after purchase. Minors shall use our products and services with the consent, guidance and supervision of their parents or guardians.

7.2 We attach importance to the privacy protection of minors and encourage parents to always play an active role in children's online experience. If you are the guardian of a minor, if you have any questions about the personal information of the minor under your guardianship, you can contact us at any time through the contact information in Article 11.2 of this Privacy Policy.

7.3 If you think that we have collected and used the personal information of minors without authorization, please contact us in accordance with the contact information in this Privacy Policy. After verification, we will delete the relevant personal information as soon as possible. If we find ourselves collecting personal information about a minor without first obtaining verifiable parental consent, we will try to delete the information as soon as possible.

7.4 In addition to dealing with the personal information of children under the age of 14 that may be involved, in accordance with the provisions of other parts of this Privacy Policy, we will also take the following measures to ensure the security of children's personal information:

(1) We will collect and use children's personal information in strict accordance with the Provisions on The Protection of Children's Personal Information Network and other relevant laws and regulations;

(2) We will appoint specialized personnel to take charge of the protection of children's personal Information in accordance with the requirements of the Regulations on The Protection of Children's Personal Information Network;

(3) When you, as the guardian, choose to use the services provided by us for the children under our guardianship, we may need to collect the personal information of the children under our guardianship from you for the purpose of providing our services to the children. You understand and agree that when you provide us with the personal information of a child under your care, you shall be deemed to have consented to our protection of the personal information of a child under your care in accordance with this Privacy Policy. We will collect children's personal information with your permission and inform you of the purpose and purpose of the collection. If you do not provide the above information, the child under your custody will not be able to enjoy the relevant services provided by us. As the guardian, you shall perform your duty of guardianship correctly, protect the safety of children's personal information, guide and inform children to avoid providing their personal information directly to us without your consent when using the services provided by us;

(4) The child or his guardian has the right to access and correct the child's personal information at any time, and may also request us to correct or delete the child's personal information. If you have any questions, comments, Suggestions or complaints about children's personal information, please feel free to contact us.

8、Third-party service

8.1 This Privacy Policy does not apply to products and services provided by third parties. MAXTOP products and services may include third party products and services, as well as links to third party websites. In general, if these products and services do not display or link to this Privacy Policy or otherwise indicate that MAXTOP is a personal information controller or a joint personal Information controller, the privacy policy of such third party shall apply when dealing with personal information.

8.2 We are not responsible for, nor can we control, how third parties collect, use, share, transfer or protect users' personal information.

8.3 To avoid misunderstanding, please abide by the service agreement of the third party and read its privacy policy.

9、Modifications and changes

9.1 You may request a copy of this privacy policy from us using the contact details listed below. We may modify or update this Privacy policy from time to time. You will be able to see our last updated privacy policy, as we will note the last updated date; The revised privacy policy will take effect from the date of publication. Please check the Privacy Policy from time to time to confirm whether we have made any changes in the way we use personal data.

9.2 If any changes to this Privacy Policy are likely to have a significant impact on your rights, we will take reasonable steps to notify you of such changes. Under the foregoing circumstances, if you continue to use our services, devices, etc., you agree to accept this revised Privacy Policy.

10、Notice and Service

10.1 If MAXTOP sends any information to you, it will be sent to the email address, mobile phone number and mailing address left by you when you register your account or purchase MAXTOP products, or pushed directly through the mobile phone system; If it is sent by means of electronic communication, your device or the electronic system you are using will be deemed to have received the message; If it is sent by express, it shall be deemed to have been delivered on the third day after the delivery.

10.2 If you have any requirements, comments, Suggestions or questions regarding this Privacy Policy or MAXTOP products, please feel free to give feedback to MAXTOP. The contact information of MAXTOP:

(1) Company name: Shenzhen Maxtop Smart Tech. Co., Ltd.

(2) Registered address: Room B418, Mingyou Procurement Center, Baoyuan Road, Xixiang Street, Baoan District, Shenzhen, China, Zip code:518100

(3) We have set up a dedicated department for personal information protection. You can contact it through the following ways: info@maxtop.asia 

 

Last update:2020/7/21