Privacy Policy Overview:

 

Welcome to Shanghai Export Tax Rebate Network (hereinafter referred to as "the Website"). We attach great importance to your privacy and personal information protection. This Privacy Policy applies to the information collected from your access and usage of the Website's products and services.

 

We strive to present this Privacy Policy in a clearer and more understandable manner to genuinely convey our intentions and ensure that you are fully aware of the purposes, potential uses, and other aspects of the information collection before you provide us with certain information, including your personal information, and allow us to process and share such information.

 

This Privacy Policy aims to help you understand what data we collect, why we collect it, what we do with it, and how we protect it. Please read this Policy carefully before using our services. If you disagree with the contents of this Policy, you will not be able to use our full services, and you should immediately cease using our products and services. By using the Website's services or products, you signify your acceptance of the contents outlined in this Policy.

 

This Privacy Policy will help you understand the following:

 Scope of Application and Definitions of Relevant Terms

 How We Collect and Use Your Personal Information

 How We Use Cookies and Similar Technologies

 How We Share, Transfer, and Publicly Disclose Your Personal Information

 How We Store and Protect Your Personal Information

 Your Rights

 Cross-Border Transfer of Your Personal Information

 Revisions to the Privacy Policy

 How to Contact Us

 

I. Scope of Application and Definitions of Relevant Terms

 

1.1 This Policy applies to your use of any of our products and services, regardless of whether inpidual privacy terms are set for those products and services, and whether you are a browsing user (visitor) or a registered user. However, please note that this Policy does not apply to:

(1) Information collected by third-party services (including any third-party websites) accessed through our services;

(2) Information collected by other companies and organizations providing advertising services on our platform.

 

1.2 Definitions of Relevant Terms:

(1) "We," "the Website," or "Shanghai Export Tax Rebate Network" refers to Shanghai Bozhu Consulting Co., Ltd. or its affiliated companies that actually provide services to you.

(2) Personal Information refers to various types of information recorded electronically or otherwise that can identify a natural person alone or in combination with other information, including but not limited to a natural person's name, biometric identifiers, company name, work background, email address, phone number, etc.

(3) Sensitive Personal Information refers to personal information that, once leaked, illegally provided, or misused, may endanger personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment, including personal identity information, bank account numbers, communication records and content, financial information, transaction information, and personal information of minors under 14 years old. You agree that your sensitive personal information will be processed according to the purposes and methods outlined in this Policy.

(4) Device refers to any apparatus used to access the Website's products or services, such as desktops, laptops, tablets, or smartphones.

(5) Affiliates and Partners refer to Bozhu's associated companies, investment holding companies, alliance members, partners, and other trusted third-party vendors, service providers, and agents.

 

II. How We Collect and Use Your Personal Information

 

2.1 Information You Proactively Provide to Us

(1) When using our specific products and services, you may need to create a personal account on the Website. During account creation, you may be required to provide data such as your mobile phone number, email address, account name, and password. After creating an account, when you further use specific products and services (e.g., enroll in courses), you may provide additional information such as your name, mobile phone number, and company name.

(2) When browsing our website to learn about our products and services, you may leave callback information, which may include your name, mobile phone number, email address, and occupation.

(3) During offline promotional activities, our staff (or those of our affiliates and partners) may distribute promotional materials and retain some of your personal information when providing product and service consultations, including your name, mobile phone number, email address, WeChat or QQ numbers, etc.

(4) Subject to compliance with relevant national laws and regulations, we may use the information received to provide the following services: pushing more accurate commercial SMS messages to you based on feature tags. If you need to cancel this authorization, you can cancel the commercial SMS we send you according to the message content prompt (e.g., by replying "TD").

 

2.2 Information Automatically Obtained from You

(1) Device Information: To provide better products and services and enhance user experience, we need to collect (including collection in the background) your information, including your device information (such as hardware model, operating system version, device configuration, unique device identifier, International Mobile Equipment Identity (IMEI), Media Access Control (MAC) address of network devices, Identifier for Advertisers (IDFA), SIM card information, Basic Service Set Identifier (BSSID), Service Set Identifier (SSID), Integrated Circuit Card Identifier (ICCID), device serial number - Serial Number (SN)), device connection information (browser type, telecommunications operator, language used), and device status information (e.g., device sensor data, list of installed device applications). For information collected from your various devices, we may associate them to enable us to provide you with consistent services across these devices.

(2) Log Information: When you use the products and services of the Shanghai Export Tax Rebate Network platform, our servers automatically record certain information, such as your usage of our products and/or services, IP address, URL of the accessed service, browser type and language used, information on downloading, installing, or using mobile applications and software, information related to communication with messaging software, and the date, time, and duration of access to the service.

(3) Location Information: When you use the products and services of the Shanghai Export Tax Rebate Network platform that have location functions, and when you enable the device's location function and use our location-based services, we may collect and process information about your actual location to enable you to obtain relevant services without manually entering your geographic coordinates. We use various technologies for location, including IP addresses, GPS, and other sensors that can provide relevant information. You can stop the collection of your location information by disabling the location function, but you may not be able to access related services or functions, or achieve the desired effects of such services.

 

2.3 Your Personal Information Collected Indirectly

When you use the services of our affiliates or partners through our products or services, you agree that we may receive, use, summarize, and analyze your personal information that they have obtained with your authorization and consent based on actual business and cooperation needs.

 

2.4 Sensitive Personal Information

For certain functions of this application, we may request your sensitive personal information. Before providing any personal information that falls under sensitive categories to Shanghai Export Tax Rebate Network, please carefully consider whether such provision is appropriate and agree that your sensitive personal information may be processed for the purposes and in the manners described in this guideline. We will collect and use your sensitive information upon obtaining your consent to fulfill functions related to Shanghai Export Tax Rebate Network's business, and allow you to opt out of the collection and use of these sensitive information. Refusing to provide such information will only affect your use of related functions and will not impact your use of this application.

(1) When you use the camera function to upload images or scan QR codes for login, we will obtain your camera permission upon your explicit consent;

(2) When you use the album function to upload and save images and videos, we will obtain your album permission upon your explicit consent;

(3) When you use the microphone function for voice queries, we will obtain your microphone permission upon your explicit consent;

(4) When you use the message push function to receive timely app notifications, we will obtain your message push permission upon your explicit consent;

(5) When you use the calendar function to access course schedules and live broadcasts, we will obtain your calendar permission upon your explicit consent;

(6) When you use the check-in and dynamic location function, we will obtain your geolocation permission upon your explicit consent to enable location services within the app;

(7) When you use the network function to watch and download courses, we will obtain your network permission upon your explicit consent;

Please understand that our functions and services are constantly updated and developed. If a function or service not covered in the aforementioned explanations collects your information, we will separately inform you of the purpose and content of the information collection through page prompts, interaction processes, website announcements, etc., to obtain your consent.

 

2.5 Purposes for Which We May Use the Information Collected During Service Provision

(1) By utilizing the collected information, we will use it for data organization, analysis, and research to enhance your experience and improve our products and services.

(2) To improve the security of your use of our products and services, we may use your information for identity verification, customer service, security precautions, fraud detection, etc., to prevent, detect, and investigate fraud, security breaches, illegal activities, or violations of our agreements, policies, or rules, thereby protecting your and our legitimate rights and interests.

(3) Based on your usage of our products or services, we may recommend products with higher relevance to you or offer trials of new products or services through methods such as phone calls. These may include, but are not limited to, products or services featured on various websites, Apps, WeChat, mini-programs, lectures, and marketing events under Shanghai Export Tax Rebate Network (or its affiliates).

(4) You may participate in surveys related to our products and services or initiated through our products and services. Your participation in these surveys is entirely at your discretion, and you can choose which information to provide.

(5) To improve our products and services, Shanghai Export Tax Rebate Network may share user usage information with third-party analysis agencies to showcase the overall usage status of our services and analyze future trends. However, these statistical information will not contain any of your personally identifiable information.

To enhance user experience, improve our services, or for other purposes with your consent, and under the premise of complying with relevant laws and regulations, we may use the personal information collected through one of our services in an aggregated form for our other services.

Please note that unless you delete or withdraw your consent (by denying our collection and use through system settings), all personal information you provide when using our services will continue to authorize us to use it within the scope of this policy during your use of our services. After you close your account, we will delete your personal information upon your request or anonymize it, except as otherwise stipulated by laws and regulations.

 

III. How We Use Cookies and Similar Technologies

When you use our services, we will store small data files called cookies on your computer or mobile device. Cookies typically contain identifiers, site names, as well as some numbers and characters. We use such information to determine whether registered users have logged in, improve product or service quality, and optimize user experience. If you do not wish to have your personal information saved in cookies, you can configure your browser to disable the cookie function. Disabling cookies may affect your access to the Shanghai Export Tax Rebate Network or your ability to fully obtain the services provided by the Shanghai Export Tax Rebate Network.

We will not use cookies for any purpose other than those described in this guide. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer, and most web browsers have a function to block cookies.

 

IV. How We Share, Transfer, and Publicly Disclose Your Personal Information

 

4.1 Sharing

(1) We do not share your personal information with any company, organization, or inpidual, except in the following circumstances:

a. With your explicit authorization or consent: After obtaining your explicit consent, we will share your personal information with other parties.

b. Sharing under legal circumstances: We may be required to share your personal information in accordance with applicable laws and regulations, legal procedures, government mandates, or judicial rulings.

c. To protect interests, property, or safety: Within the scope required or permitted by law, we may need to provide your personal information to third parties to protect the interests, property, or safety of Shanghai Export Tax Rebate Network, its users, or the public from harm.

d. Sharing with our affiliated companies: Your personal information may be shared among our affiliated companies. We will only share necessary personal information, and such sharing is subject to this Privacy Policy. If an affiliated company intends to change the purpose of processing personal information, it will again seek your authorization and consent.

e. Sharing with authorized partners: To provide you with more complete and high-quality products and services, some of our services are provided by authorized partners. We may share certain personal information with our partners to enhance customer service and user experience. We will only share your personal information for legitimate, proper, necessary, specific, and explicit purposes, and only the information necessary for providing the service will be shared. We will sign strict confidentiality agreements with our partners, requiring them to handle your personal information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures. Our partners are not authorized to use the shared personal information for any other purpose. If you refuse to allow our partners to collect the necessary personal information for service provision, you may not be able to use that third-party service on Shanghai Export Tax Rebate Network.

(2) Currently, our authorized partners include the following types:

 Advertising, consulting service providers/advertisers: We will not share your personal information with advertising or consulting service providers without your authorization.

 Suppliers, service providers, and other partners: We share information with suppliers, service providers, and other partners who support our business globally, including those providing services such as express delivery, software development, and data storage. We sign strict confidentiality agreements with the companies, organizations, and inpiduals with whom we share personal information, requiring them to handle personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

(3) Some products or services may be provided by third parties or jointly provided by us and third parties. Therefore, sharing your information is necessary to provide the products or services you need. For the sole purpose of realizing this service, we will share your personal information with third-party partners (including third-party service providers, agents, advertising partners, application developers, telecommunication operators, such as communication service providers who send SMS or push notifications on our behalf) who may not be located in your jurisdiction. These parties will process the information in accordance with our instructions, user authorization agreements, and other confidentiality and security measures, and use it for the following purposes:

(1) To provide you with our services;

(2) To achieve the purposes described in the "How We Use Your Personal Information" section;

(3) To understand, maintain, and improve our services.

If you agree to us sharing your information with third parties, we will adopt encryption and anonymization methods to ensure the security of your information.

 

4.2 Transfer

We will not transfer your personal information to any company, organization, or inpidual other than Shanghai Export Tax Rebate Network and its affiliates, except in the following circumstances:

(1) With your explicit authorization or consent in advance;

(2) To comply with legal requirements, legal procedures, mandatory government requirements, or judicial rulings;

(3) If we or our affiliates are involved in transactions such as establishment, merger, spin-off, liquidation, acquisition or sale of assets or businesses, your personal information may be transferred as part of such transactions. We will ensure the confidentiality of such information during the transfer and require the new company or organization holding your personal information to continue to be bound by this Privacy Policy. Otherwise, we will require such company or organization to seek your authorization and consent again.

 

4.3 Public Disclosure

We will not publicly disclose your personal information without your explicit consent.

However, under circumstances based on laws, legal procedures, litigation, or mandatory requirements of government authorities, we may disclose your personal information to authorized authorities. We guarantee that when the above circumstances occur, we will require the requesting party to present valid legal documents and take security measures that comply with laws and industry standards for the disclosed information.

 

4.4 Exceptions to Authorization and Consent for Sharing, Transferring, and Publicly Disclosing Personal Information

According to relevant laws and regulations, we may collect and use some necessary personal information without obtaining your authorization and consent in the following circumstances:

(1) Directly related to national security and national defense security;

(2) Directly related to public safety, public health, and significant public interests;

(3) Directly related to criminal investigation, prosecution, trial, and judgment execution;

(4) Necessary to protect the vital legitimate rights and interests of you or other inpiduals, but it is difficult to obtain consent from the inpidual;

(5) The personal information collected is publicly disclosed by you;

(6) Your personal information is collected from legally disclosed information, such as legitimate news reports and government information disclosure;

(7) Necessary for signing and fulfilling contracts upon your request;

(8) Necessary for maintaining the safe and stable operation of Shanghai Export Tax Rebate Network's products and services, such as detecting and handling faults in products or services;

(9) Other circumstances stipulated by laws and regulations.

 

V. How We Store and Protect Your Personal Information

 

5.1 Location of Information Storage

In accordance with laws and regulations, we store your personal information collected within the territory of the People's Republic of China. Currently, we do not use, store, share, or disclose your personal information in cross-border operations or transfer it overseas.

If our business changes in the future and we need to transfer your personal information to other countries or regions, where there may be different data protection laws or even no relevant laws, we will ensure that your personal information is protected to the same level as within the territory by complying with relevant laws and regulations. We will also inform you of the types, purposes, recipients, security measures, and security risks of the personal information being transferred overseas, and conduct security assessments or registrations as required by laws and regulations before transferring the information overseas.

 

5.2 Duration of Information Storage

In general, we retain your personal information only for the period necessary to achieve the purpose. For example:

Mobile Phone Number: If you need to use the services of Shanghai Export Tax Rebate Network, we need to keep your mobile phone number to ensure your normal use of the service and to facilitate timely customer service contact when you have questions. After you deactivate your account on Shanghai Export Tax Rebate Network, we will delete the corresponding information.

Course Information: If you purchase or try out related courses, we store information related to the course, such as orders, learning progress, and playback records. After your account deactivation is approved, we will delete the relevant information.

In the case of cessation of operation of our products or services, we will notify you through push notifications, announcements, telephone contacts, etc., and delete your personal information or anonymize it within a reasonable period ("Anonymization" refers to the technical processing of personal information to make it impossible for the subject of personal information to be identified, and the processed information cannot be restored. Information obtained after the anonymization of personal information does not constitute personal information).

 

5.3 Information Protection

 

5.3.1 Technical Measures and Data Security Measures

We strive to adopt various physical, electronic, and administrative security measures that meet industry standards to protect the security of your personal information. We actively establish data classification and grading systems, data security management specifications, and data security development specifications to manage and regulate the storage and use of personal information, ensuring that we do not collect personal information unrelated to the services we provide.

We implement comprehensive security controls on data through confidentiality agreements with those who access the information, as well as monitoring and auditing mechanisms. This prevents unauthorized access, disclosure, use, modification, damage, or loss of your personal information.

We have implemented industry-standard security measures to protect the personal information you provide, safeguarding against unauthorized access, disclosure, use, modification, damage, or loss of data. We take all reasonable and practical measures to protect your personal information. For example, data exchanged between your browser and Shanghai Export Tax Rebate Network (such as credit card information) is protected by SSL encryption; we use encryption technology to ensure data confidentiality; we employ trusted protection mechanisms to prevent malicious attacks on data; we deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we conduct security and privacy protection training sessions to enhance employee awareness of the importance of protecting personal information.

 

5.3.2 Security Certifications

We have established a well-coordinated communication mechanism with regulatory agencies and third-party evaluation institutions to promptly resist and address various information security threats, providing comprehensive protection for your information security.

 

5.3.3 Incident Response for Security Breaches

We strive to ensure the security of any information you send to us, but please understand that due to technological limitations and various malicious tactics prevalent in the internet industry, it is impossible to guarantee 100% security of information at all times. You should be aware that the systems and communication networks you use to access our services may encounter issues beyond our control. To prevent security incidents, we have established appropriate early warning mechanisms and emergency response plans. In the unfortunate event of a personal information security breach, we will promptly inform you in accordance with legal and regulatory requirements of: the basic situation and potential impact of the security incident, the measures we have taken or will take to address it, suggestions for you to independently prevent and mitigate risks, and remedial measures for you. We will immediately activate our emergency response plan to minimize losses. We will promptly notify you of the incident via phone, push notifications, or other means. When it is difficult to notify users inpidually, we will issue an announcement in a reasonable and effective manner.

Furthermore, we will proactively report the handling of personal information security incidents to regulatory authorities as required and closely cooperate with government agencies in their work.

 

VI. Your Rights

 

In accordance with relevant Chinese laws, regulations, standards, as well as common practices in other countries and regions, we safeguard your rights to exercise the following with respect to your personal information.

 

6.1 Right of Access. You can log in to your personal account at any time to access or edit your personal information, change your password, add security information, link accounts, or verify your identity.

 

6.2 Right of Correction. Upon verification of your identity and without affecting the objectivity and accuracy of the information, you have the right to correct or update incorrect or incomplete information. You can make corrections on our website or client application, or in specific cases, especially when data is erroneous, submit your correction request to us through the contact information provided at the end of this policy, requesting us to correct or update your data, unless otherwise stipulated by laws and regulations. However, for security and identity verification purposes, you may not be able to modify certain initial registration information submitted during registration.

 

6.3 Right of Deletion. You can submit a request to us through the contact information provided in this Privacy Policy to delete your personal information, for example, if you no longer require our services, except where the data has been anonymized or otherwise stipulated by laws and regulations.

 

6.4 Right to Modify or Revoke Your Authorization. If you wish to change the scope of authorization for related functions (e.g., location, contacts, camera), you can modify your personal settings on your hardware device or through the relevant function settings in our products or services. If you encounter operational issues during this process, you can contact us through the methods provided at the end of this policy.

After you cancel the authorization for the collection of relevant personal information, we will no longer collect such information and will be unable to provide you with the corresponding services mentioned above. However, you acknowledge and agree that unless you exercise the aforementioned "Right of Deletion," your action will not affect our processing and storage of your personal information based on your previous authorization.

 

6.5 Right of Account Cancellation. You can cancel your account by contacting our customer service or through other methods we have publicly announced (unless otherwise stipulated by laws and regulations). Once your account is cancelled, you will no longer be able to use all the products or services we provide, so please proceed with caution. To protect your or others' legitimate rights and interests, we will consider your usage of our various products when assessing your cancellation request. For example, if you have unfinished courses or enrolled courses that have not yet started, we will not immediately support your request but will prompt you to take corresponding actions first. Unless otherwise stipulated by laws and regulations, after account cancellation, all information in your account will be cleared, and your personal information will be deleted or anonymized upon your request. For specific details on the cancellation process and timelines, please refer to the "Shanghai Export Tax Rebate Network Account Cancellation Guidelines."

 

6.6 Right to Be Notified in Advance of Service Termination. We are committed to being with you always. If, due to special circumstances, some or all of our products and services are forced to cease operation, we will notify you 15 days in advance through the main page of the product or service, in-site messages, email, or other appropriate means that can reach you. We will stop collecting your personal information and will delete or anonymize your personal information held in accordance with legal requirements, unless otherwise stipulated by laws and regulations.

 

VII. How Your Personal Information is Transferred Globally

 

In principle, the personal information collected and generated by us within China will be stored within China. If some products or services involve cross-border transmission of your personal information, we will strictly comply with the provisions of laws and regulations and ensure the security of your personal information.

 

VIII. Updates to This Privacy Protection Policy

 

Our privacy policy may be subject to changes. Without your explicit consent, we will not diminish the rights you are entitled to under this privacy policy. Any changes made to this policy will be posted on this page.

For significant changes, we will provide more prominent notifications, including through announcements on the official website of Shanghai Export Tax Rebate Network or even pop-up prompts to you. The significant changes referred to in this policy include but are not limited to:

(1) Significant changes in our service model, such as the purpose of processing personal information, the types of personal information processed, and the ways in which personal information is used;

(2) Major changes in our ownership structure or organizational setup, such as ownership changes resulting from business adjustments, bankruptcies, mergers, or acquisitions;

(3) Changes in the primary parties involved in the sharing, transfer, or public disclosure of personal information;

(4) Significant changes in your rights and the ways in which you exercise them regarding personal information processing;

(5) Changes in the responsible department, contact information, and complaint channels for handling personal information security;

(6) When the personal information security impact assessment report indicates a high risk.