Privacy Policy of 51Earth
[Foreword] 51Earth (“we” or “us”) always attaches great importance to protecting the personal data and privacy security of those who use our products and services (collectively, “users” or “you”). We may collect and use your personal data when you use our products and services. Through this Privacy Policy of 51Earth (this “Policy”), we hope to explain to you the rules and other related matters in our collection and use of your personal data, so that you can better protect your rights. For the purpose of this Policy, “51Earth” refers to 51WORLD High Technology (HK) Co., Limited and its affiliates.
[Special tips] This Policy applies to 51Earth website and all online service and products provided by 51Earth that either display or link to this Policy. By using any single service or product provided by us, you agree to accept the terms of this Policy and the terms of the specific privacy policy formulated for such single service or product, if any (the “Specific Terms”), in which case both the Specific Terms and this Policy shall bind upon you. In case of any discrepancy between the Specific Terms and this Policy, the Specific Terms shall prevail to the extent of its scope of jurisdiction. If any single service or product provided by us is not applicable to this Policy, we will explicitly exclude the application of this Policy in such single service or product in an appropriate manner.
Before using various services of 51Earth, please carefully read this Policy, especially the terms in bold, and make sure you full understand it. By starting to use any service of 51Earth or submitting your personal data to 51Earth, you acknowledge that you fully understand and agree to this Policy. If you have any question, opinion or suggestion regarding the content of this Policy, you may contact us through the contact methods shown on the official website of 51Earth.
This Policy explains how 51Earth processes your personal data, but it may not cover all possible scenarios of data processing.
This Policy is formulated for the purpose of helping you understand:
1. How does 51Earth collect and use your personal data?
2. How does 51Earth use cookies or similar technologies?
3. How does 51Earth share, transfer or discloses your personal data?
4. Your rights and the methods to exercise your rights
5. How does 51Earth protect and retain your personal data?
6. How does 51Earth process personal data of minors?
7. How is your personal data transmitted globally?
8. How is this Policy updated?
9. How can you contact 51Earth?
1. How does 51Earth collect and use your personal data?
1.1 We collect your personal data mainly for the purpose of making it easier and more satisfactory for you and other users to use 51Earth services.
1.2 We collect and obtain your personal data from the following sources:
1.2.1 The information provided by yourself. For example:
(a) the information you provide to us when you register an account for 51Earth services or use 51Earth services; or
(b) the information you share with third parties through 51Earth services, and the information stored when you use 51Earth services.
Please note that if you upload or post any information in the public area in 51Earth services, or disclose your information in your response to any information uploaded or posted by other users, such information may be collected and used by other users. Once you find that any other user has improperly collected or used your information, you may contact us through the reporting methods specified herein.
1.2.2 Your information shared by third parties. Third parties may provide the shared information about you when they use 51Earth services.
1.2.3 Your information obtained by us. We may collect, summarize and record information of you when you use 51Earth services, such as log information, location information and device information.
1.3 We collect and use your personal data of the following types for the following purposes:
You understand and agree that we hope to provide you with perfect services, so we will continuously improve our services. It means that, with the iteration, expansion, upgrade, etc. of our services, we may constantly introduce new services or business functions or re-partition business functions, and thus we may need to collect new personal data of you, or change the purpose or method of using your personal data. However, if we intend to use your personal data for any other purpose not specified herein, or to collect any additional personal data of you not mentioned herein, we will obtain your prior consent by giving a notice on the page of our service, or informing you through interactive processes, or posting an announcement on the website, or by other means in accordance with the law. During this process, you may contact us through the reporting methods specified herein, and we will provide you with feedbacks as soon as possible.
1.3.1 To ensure your successful registration and login
In order to provide you with continuous and stable services and ensure information security during your use of 51Earth services, we need you to provide us with your basic registration or login information, such as your name, position, employer, address, phone number, email address, username and password. Nevertheless, in some of ours service, you may not need to register as a user of 51Earth and provide the said information if you only need to use basic functions such as browsing and searching. You can also fill in or supplement your information during your registration, login or use of our services, which will help us provide you with personalized and better service experience, and enable us to market and promote products or send service notices to you, or communicate with you in business, or conduct user profiling analysis. Subject to the specific service you actually use and related agreements (if any), you refusal to provide such information, however, will not affect your use of basic functions of 51Earth services.
1.3.2 To achieve identity authentication
As required by relevant laws, regulations or regulatory requirements, or in order to meet the needs of user identity verification, system and service security and other specific service functions, we may need you to provide us with your real identity information (such as name, ID number, passport, driver’s license, household register), biometric information (either static or dynamic) or other identity information for identity authentication. If you don’t provide such information, we will not be able to provide you with relevant functions and service. For the purpose of identity authentication, you hereby agree and authorize us to provide, query or verify the identity information provided by you to/with relevant identity authentication agencies (such as personal credit agencies, governmental departments, etc.) on our own or through a third party. Please note that your identity information, biometric information, etc. are sensitive personal data, so you shall provide them with caution. Subject to the specific service you actually use and related agreements (if any), your refusal to provide them may lead to your inability to access relevant services, but it will not affect your use of other functions and services.
1.3.3 To maintain normal operation of basic functions
During your use of our services, we may directly or indirectly collect, store and associate the information about the services you use and the methods of using such services, including but not limited to log information and device information, so that we can provide you with browsing, searching and other basic functions, identify abnormal account logging, understand product suitability, ensure the network and operational security of our services and maintain the normal operation of the basic functions. (In order to collect the said basic personal device information, we will apply for permission to access your device information. We collect such information for the purpose of providing you with our basic services and basic functions, and your refusal to give the permission may lead to your inability to use some of 51Earth services).
Please note that merely device information or log information can’t identify a specific natural person. However, if we combine such non-personal data with other information to identify a specific natural person, or use it in combination with personal data, such non-personal data will be regarded as personal data during the period of combined use. Unless it is otherwise authorized by you or required by laws and regulations, we will anonymize and de-identify such non-personal data, which will be processed and protected as personal data in accordance with this Policy during the period of combined use.
1.3.4 To provide you with interactive and publishing services (if any)
When you use 51Earth services, upload and/or post information, or have interactions with other users (such as posting or replying to any comment), we will collect the information you upload, post or form, and use your email address, net name, profile photo (if any) and the content you post for display purpose.
If you express an interest in obtaining additional information about our services, including using trial functions of our products, joining our partner program or similar functions, we may ask you to provide us with your contact information, such as your name, position, employer, address, phone number, email address.
If you participate in any 51Earth event, we may, with your consent, scan your certificate of participation, which will provide us with your information such as name, position, employer, address, country, phone number and email address.
If you participate in any 51Earth event, we may, with your consent, scan your certificate of participation, which will provide us with your information such as name, position, employer, address, country, phone number and email address.
1.3.5 To enable you place an order or make payment or to deliver goods or services to you (which will be available in future)
(a) When you order any product and/or service online from 51Earth services, we will generate an order to purchase the product and/or service for you through the system. During the process of placing orders, you need to provide at least the recipient’s identity information. Otherwise, we may not be able to deliver the product and/or service to you. If you order goods or service for any other person through 51Earth services, you need to provide the identity information of the actual purchaser. Before providing us with such information, you need to ensure that you have obtained his/her consent.
(b) In order to display to you the transaction information of your account and ensure transaction security, we will collect information generated by you during your use of 51Earth services (such as information about the goods or services you purchased, the specific order number, the time when the order is created, the transaction amount), so that we can display it to you and facilitate your order management.
(c) In order to enable you make payment, or to deliver goods or services to you, confirm your transaction status and provide after-sales and dispute resolution services to you, we will collect your account number, order, transaction and payment information related to the transaction progress through your trading partners, payment institutions, etc., or share your transaction information with the said service providers.
1.3.6 To provide you with customer service or other user response functions (if any)
We may require you to provide necessary personal data to match and verify your user identity when you contact our customer service personnel or use other user response functions (such as submitting any in-sales or after-sales application, putting forward any complaint or suggestion on personal data protection, or having any other customer complaint or needs), so as to ensure the security of your account and system. We may also retain your contact information (the contact information you use when you contact us or other contact information you provide to us initiatively), the records and content of your communication/call with us, and other necessary information related to your needs, so as to contact you, or help you solve problems, or record the results of problem solving.
1.3.7 To collect your person data indirectly
We may, to the extent permitted by law, obtain relevant services from third parties. For example, we may purchase data analysis service from other companies to support the services we provide to you. Based on the 51Earth services you choose to use, we may obtain from our affiliates and third-party partners relevant information that you authorize to share. For example, when you log in to 51Earth services by using an account opened with a third-party platform, we will obtain relevant information under the third-party account based on your authorization (including the name of the registered account, etc., subject to the content of your authorization), and bind your third-party account with your 51Earth services account after you agree to this Policy, so that you can directly log in to and use 51Earth services through the third-party account. We will collect and use your said information, as long as it conforms to relevant laws, regulations and any agreements with our affiliates or third-party partners, and we are certain that the information provided by them is legally sourced.
1.3.8 To provide you with security
In order to improve the security when you use the services provided by us or our partners, protect personal and property security of you, other users or the public, better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks and network intrusions, and more accurately identify violations of laws and regulations or relevant agreement in respect of 51Earth services, we may collect, use or integrate your account information, transaction information, device information, log information, as well as your information shared by our affiliates and partners under your authorization or in accordance with the law, so that we can comprehensively judge the risks related to your account and transactions, conduct identity verification or detection, prevent security incidents, and take necessary measures such as recording, auditing, analysis and disposal in accordance with the law.
1.3.9 You understand and agree that some services may require you to give us permissions for access your device in order to collect and use the information involved.
In some cases, you may choose not to provide such personal data to us. If you choose not to provide it, however, 51Earth may not be able to provide you with relevant products or services, or respond to or resolve the problems you have encountered.
1.3.10 You understand and agree that 51Earth may directly collect and use your non-identifying data as well. For the purpose of the preceding sentence, “non-identifying data” refers to the data that can’t be used to determine a person’s identity. For example, we may collect non-identifying data such as aggregated statistical data, website visit, usage of products and functions, for the purpose of understanding how users use our website, products and services and conducting classification analysis related to user portraits. We will try our best to separate your personal data and your non-identifying data, and use these two types of data separately. If personal data is mingled with non-identifying data, it will still be regarded as personal data for processing purpose.
1.3.11 Circumstances where we may collect your information without your consent
According to relevant laws and regulations, we may collect your information without your consent under the following circumstances:
(a) where it is directly related to national security or national defense security;
(b) where it is directly related to public safety, public health and major public interests;
(c) where it is directly related to criminal investigation, prosecution, trial and enforcement of judgments;
(d) where it is difficult to obtain your consent but it is indeed necessary for the purpose of safeguarding your or other individuals’ life and property or other significant legitimate rights and interests;
(e) where the personal data collected is made public by yourself;
(f) where it is necessary for signing and fulfilling the contract according to your requirements;
(g) where the personal data is collected from legally-disclosed information, such as legitimate news reports or disclosed government information;
(h) where it is necessary for conducting legitimate news reporting; or
(i) other circumstances stipulated by laws and regulations.
1.3.12 Tips on sensitive personal data
“Sensitive personal data” refers to personal data which, once leaked or illegally used, can easily harm the personal dignity or endanger the personal or property security of a natural person. Please note that the information provided by you or collected by us as mentioned above may contain your sensitive personal data, such as your ID number, personal biometric information (either static or dynamic), bank account, communication records and content, property information and transaction information. You agree that we can process your sensitive personal data for the purposes and by the methods specified herein.
2. How does 51Earth use cookies or similar technologies?
2.1 Cookies
To ensure the normal operation of our websites, we sometimes store small data files called cookies on computers or mobile devices. Cookies are a kind of plain text files stored on computers or mobile devices by the network server. The content of cookies can only be retrieved or read by the server that creates it. Each cookie is unique to your web browser or mobile app. Cookies usually contain identifiers, site names, some numbers and characters.
51Earth invokes cookies for the same purpose as most websites or internet service providers, that is, to improve user experience. With the aid of cookies, websites can remember a user’s single visit (using session cookies) or multiple visits (using permanent cookies), and save settings such as language, font size and other browsing preferences in computers or mobile devices. This means that users do not need to reconfigure their preference settings on each visit. 51Earth will not use cookies for any purpose other than those stated herein. However, you can manage or delete cookies based on your preferences, or clear all cookies stored on your computer, and most web browsers have a feature to block cookies. If you do so, it may affect your safe access to our websites in some cases, and you may need to change your user settings every time you visit our websites.
2.2 Web beacons and pixel labels
In addition to cookies, we also use web beacons, pixel labels and other similar technologies on the website. For instance, the emails sent by 51Earth to you may contain a URL that links to the content of the 51Earth website. If you click on the link, we can track this click to understand your product and service preferences and improve our customer service. A web beacon is usually a transparent image embedded in a website or email. By using pixel labels in an email, we get to know whether the email has been opened. If you do not want your activities to be tracked in this way, you can contact us for unsubscription at any time through the contact information shown on 51Earth website.
By using our website, you agree that we use cookies, web beacons and pixel labels as described above.
3. How does 51Earth share, transfer or discloses your personal data?
3.1 We may share your personal data with our affiliates, business partners, third-party service providers (such as technical support service providers) in accordance with laws and regulations, but we will only share your personal data for lawful, legitimate, necessary, specific and explicit purposes and only share the portion of your personal data which is necessary for providing our service. Our partners and third-party service providers will have no right to use your personal data so shared for any purpose other than providing the services. We will investigate the data security environment of the companies, organizations and individuals with whom we share your personal data, conclude confidentiality agreements with them, and require them to process your personal data according to our instructions, this Policy and any other confidentiality and security requirements. To be specific, we will share your personal data with any third party other than 51Earth for any of the following purposes:
(a) Necessary sharing to achieve the functions of our products and/or services. In some cases, we may need to share your information with third parties to achieve the functions of our products and/or services, so that you can use the services you need to use normally, including: (1) sharing your personal data with persons who provide you with the access to our services (such as your employer); (2) sharing transaction order and payment amount information with third-party payment institutions that provide payment services to you; (3) sharing your information necessary for real name authentication with real name authentication service providers; (4) any other necessary sharing with other suppliers, service providers and business partners in respect of our services/functions.
(b) Necessary sharing with some of our partners. In order to ensure the smooth development of company business, meet your requirements, fulfill our obligations and exercise our rights under relevant user agreements or this Policy, or comply with relevant law and regulations, we may need to share your information with some of our business partners, including: (1) sharing your log information and device information with partners who provide data services (including online advertising monitoring, data statistics and data analysis) to us; (2) sharing the statistical data on your product usage (such as collapses and crashes) with partners who provide product analysis services (including application collapse analysis, network performance analysis and domain name resolution optimization) to us; (3) sharing your relevant information (including device information) with partners who provide marketing services (including advertising and marketing) to us; (4) sharing with the partners who entrust us with promotion service how many persons have seen their promotional information or purchased products after seeing such information, or providing them with non-identifying statistical information to help them understand their audience or customers; (5) sharing, upon reasonable request, your personal data with third parties (such as legal advisors and data security professionals) for the purpose of protecting our rights, users, systems and service; (6) any other necessary sharing with some of our partners.
(c) Necessary sharing with our affiliates. In order to provide you with unified services under a unified account system and facilitate your unified management, personalized recommendations and system and account security, your personal data may be shared between us and our affiliates when necessary. For example, 1) in order to help you save time and simplify the procedures, you can log in to some single services without the need for duplicate registration after you register our 51Earth account, and your account information will be shared within our and our affiliates’ products; 2) in order to provide you consistent and personalized browsing, advertising and other service experience in our and our affiliates’ products and/or services, you understand and agree that your account information, device information, relevant browsing data and other information reflecting your usage habits and interests may be shared with our affiliates.
(d) Sharing with any person you ask us to share your data with (for example, you upload your data to a public forum where such data is publicly shared).
3.2 If we or any of our affiliates encounters merger, division, liquidation, acquisition or sale of assets or business, or similar transactions, your personal data may be transferred as part of such transactions. We will ensure the confidentiality of such data at the time of transfer and try our utmost to ensure that new company(ies) or organization(s) holding your personal data continue to be bound by this Policy. Otherwise, we will require the company(ies) or organization(s) to seek your consent again.
3.3 We will disclose your personal data only under the following circumstances and only after we take security measures in line with the industry standard:
(a) We may, based on your needs, disclose your designated information in the manner that you have explicitly agreed to.
(b) If it is so requested by laws, regulations, mandatory administrative or judicial requirements, we may disclose such type of your information in such manner as requested. Subject to relevant laws and regulations, when we receive the said request for disclosure of your information, we will require the information recipient to present legal documents, such as subpoenas or letters of investigation. We firmly believe that the information requested from us should be kept as transparent as possible to the extent permitted by the law. We have prudently reviewed all requests to ensure that they have legal basis and that we only provide such portion of data that law enforcement departments have the legal right to obtain for investigative purposes.
3.4 If your information falls under the “circumstances where we may collect your information without your consent” mentioned above, we may share, transfer or publicly disclose your personal data without your prior consent.
3.5 According to the law, any sharing, transferring or disclosing the personal data that has undergone de-identification processing, which leads to the data recipient’s inability to restore the personal data and re-identify the information subject, does not constitute sharing, transferring or public disclosure of the personal data. Therefore, we don’t need to notify you and obtain your consent for storing and processing of such data.
4. Your rights and the methods to exercise your rights
4.1 You should ensure that all personal data submitted by you is accurate, while we will do our best to maintain the accuracy and completeness of your personal data and update it in a timely manner.
4.2 If required by applicable laws, you may:
(a) have the right to access certain personal data about you in our possession.
(b) request us to update or correct your inaccurate personal data.
(c) refuse or restrict our use of your personal data.
(d) request us to delete your personal data.
(e) revoke your consent at any time when 51Earth processes your personal data based on your consent; provided that such revocation will not affect the legality and effectiveness of our processing of your personal data based on your consent before the revocation, nor will it affect our processing of your personal data based on other legitimate reasons.
(f) request us to cancel your account at any time. After your account is cancelled, we will delete or anonymize your personal data.
4.3 If you intend to exercise the said rights, you may contact us through the contact information shown on the official website of 51Earth. For the sake of safety, you may need to submit a written request. If we reasonably believe that such request is deceptive, unenforceable or infringes upon the privacy rights of others, we will reject such request.
5. How does 51Earth protect and retain your personal data?
5.1 We attach great importance to the security of your personal data. We will take appropriate measures from the physical, administrative and technical aspects to protect your personal data from unauthorized access, disclosure, use, modification, damage or loss. For example, we will use encryption technology to ensure the confidentiality of your personal data, use protection mechanisms to prevent data from being maliciously attacked, deploy access control mechanisms to ensure that only authorized persons can access personal data, and arrange security and privacy protection training courses to enhance employees’ awareness of personal data protection. We will try our best to protect your personal data, though no security measures can be flawless.
5.2 We will retain your personal data for such period as necessary to achieve the purposes specified herein, unless the retention period is required or permitted to be extended by law. Due to different scenarios, products and services, the data retention period may vary. The considerations for us to determine the retention period are as follows: the period the personal data needs to be retained to achieve the business purpose (including providing products and services, maintaining transaction and business records, controlling and improving the performance and quality of products and services, ensuring the security of systems, products and services, responding to possible user queries or complaints, problem localization); whether the user agree to a longer retention period; whether there is any special requirement for data retention in laws, contracts, etc. As long as your account is necessary for us to provide you with services, we will retain your registration information. You may also choose to cancel your account. After you cancel your account or voluntarily delete the said information, we will no longer commercially use your personal data, but we may use your personal data after anonymization.
6. How does 51Earth process personal data of minors?
Our products, websites and services are mainly aimed at adults. If you are under 13 years old, please do not use our services. If you are a minor between the ages of 13 and 18, please read this Policy together with your legal guardian and obtain the consent of your legal guardian before using our services. For the personal data of minors collected by us with the consent of their parents, we will use or disclose such data only to the extent permitted by law, or explicitly agreed upon by their parents or guardian, or when it is necessary to protect the minors. If we find that we have collected personal data of minors without obtaining verifiable parents’ consent in advance, we will try to delete the data as soon as possible. If you are a parent or guardian and believe that your minor child has provided us with his/her personal data without your consent, please contact us to delete it through the contact information shown on 51Earth website.
7. How is your personal data transmitted globally?
In principle, the personal data we collect and generate within the territory of Hong Kong will be stored in Hong Kong. If some products or services involve cross-border transactions and we need to transmit your personal data to foreign countries, we will do so strictly following relevant laws and regulations and ensuring the security of your personal data.
8. How is this Policy updated?
51Earth reserves the right to update or modify this Policy from time to time. In case of any change in our privacy policy, we will publish the latest version of our privacy policy here. If we make major changes to our privacy policy, we may also notify you of the change through different ways, such as posting a notice on our website or send a separate notice to you.
9. How can you contact 51Earth?
If you have any question, opinion or suggestion, please send an email to us at 51earth@51earth.com or call us at (+86) 010-84388170.