EasyAnalysis Privacy Statement

This EasyAnalysis Privacy Statement (“Privacy Statement”) only applies to the could service “EasyAnalysis” (the “Services”) provided by Dmall Inc. and its affiliates (“Dmall”, “we” or “us”) to its users. This Privacy Statement does not apply to products/ Services provided by Dmall’s business partners, or products/ services of Dmall that have separately published their own privacy and security statements. Our business partners will provide separate privacy statements applicable to their products/ services.

This Privacy Statement sets out the followings:

    I.     Rules for the Collection and Use of Personal Information

    II.    How We Use Cookies and Similar Technologies

    III.   Legal Basis for Processing Personal Information

    IV.   How We Protect your Personal Information

    V.    Data Retention

    VI.   Your Rights Over Your Personal Information

    VII.   Information Relating to Minors

    VIII. International Data Transfers

    IX.   Changes to this Privacy Statement

    X.    How to Contact Us

    XI.   Glossary of Concepts and Terminologies

Our Services are numerous and are optimized from time to time, and the personal data relied on by specific products/ services may vary, or may be adjusted after the release of this Privacy Statement. Therefore, in addition to this Privacy Statement, we will also explain to you the processing of personal data under certain specific products/ services through privacy reminders and supplementary statements. When using these products/ services, please pay attention to the relevant reminders or statements. Continuing to use our Services after we update this Privacy Policy (we will promptly remind you of the update) indicates your agreement to the contents of this Privacy Policy (including the updated) and to our collection, use and storage of your personal data in accordance with this Privacy Policy.

I. Rules for the Collection and Use of Personal Information

In order to access the functions of our Services, you are required to authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our Services.

Please be aware that our Services are provided through various means..

1.How We Collect Your Personal Information

(1) User registration

We need you to provide your office email address, company name and department information, as well as name, phone number and other information that may be required to open a product account for you. The above registration information is your “account information” which will help us to confirm your identity. If you do not provide such information, you may not be able to use the basic functions of our Services.

(2) Display of account information

If you already have an account of EasyAnalysis, we may display your above personal data when you use EasyAnalysis, including displaying your personal data and operation data through your account. We will respect the choices you made in your account settings.

(3) Service log information

During your use of our Services, in order to protect your account security, identify abnormal account status, understand product suitability, we may automatically collect your usage information and store as web log information. When you use our /Services, we will automatically collect your detailed usage of our Services and save them as service logs, including information related to browsing, click-to-view, search queries, language used, and date and time of access.

Please note that individual service log information is information that cannot identify a specific natural person. 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 considered personal data for the duration of the combined use.

2. How We Use Your Personal Information

In case the information you provide contains personal data of other users, you shall ensure that you have obtained legal authorization before providing such personal data to Dmall. Enterprise users shall collect, use, provide and delete personal data of employee users in accordance with the agreement with employee users within the scope permitted by laws, regulations and regulatory authorities.

We will obtain your prior consent if we use the information collected for purposes other than those stated in this Privacy Statement; for other specific purposes; or if we obtain your personal data from a third party on our own initiative.

You fully understand and agree that your authorized consent is not required for us to collect and use your personal data, and that we may not respond to your requests for correction/correction, deletion, cancellation, withdrawal of consent, request for information when:

a) related to national security, national defense and safety;

b) related to public safety, public health, significant public interest;

c) in connection with judicial or administrative law enforcement, such as crime investigation, prosecution, trial and judgment enforcement;

d) to protect your or other individuals' life, property and other significant legitimate rights and interests but it is difficult to obtain your consent;

e) personal data that you disclose to the public on your own;

f) personal data collected from lawful public disclosures, such as lawful news reports, government information disclosure and other channels;

g) as necessary for the execution and performance of agreements or other written documents with you;

h) as necessary to maintain the safe and stable operation of the Services provided, such as the detection and disposal of Service failures;

i) necessary for legitimate news reporting;

j) necessary for academic research institutions to conduct statistical or academic research in the public interest, and to de-identify personal data contained in the results of academic research or descriptions provided to the public; and

k) other circumstances as permitted or required by the applicable laws and regulations.

Please be aware that, in accordance with applicable laws, if we take technical and other necessary measures to process personal data in such a way that a particular individual cannot be re-identified by the data recipient and cannot be recovered, or we may de-identify the information we collect for research, statistical analysis and prediction purposes to improve the content and layout of our Services, to provide products/ services to support business decisions, and to improve our products and Services (including the use of anonymized data for machine learning or model algorithm training), then such processed data may be used without further notice to and consent from you.

3. How we entrust the Processing of, Share, Transfer and Publicly Disclose Your Personal Information

(1) Entrusted Processing

We entrust certain specific modules or functions of our Services to external suppliers, such as account verification, recording extraction, face recognition processing, etc.

We will enter into strict confidentiality agreements with companies, organizations and individuals with whom we entrust the processing of personal data, requiring them to handle personal data in accordance with our requirements, this Privacy Statement and any other relevant confidentiality and security measures.

(2) Sharing

We will not share your personal data with any other third-party company, organization, or individual unless we have your express consent to do so.

Currently, we may seek your consent to share your personal data in the following circumstances:

a) sharing under legal circumstances: We may share your personal data as required by laws or regulations, or for a litigation, dispute resolution purpose, or as required by administrative or judicial authorities as required by law.

b) sharing with enterprise users who have opened sub-accounts for employee accounts: In order to manage the verification of the work status of employees affiliated with the relevant enterprise users, we will share the information provided under the relevant functions of employee accounts with enterprise users based on the content of the products/Services they have chosen to use.

c) Sharing with affiliates: Your personal data may be shared with our affiliates and/or their designated service providers in order to facilitate our provision of products and services to you, to identify anomalies in member accounts, and to protect the personal property of our affiliates or other users or the public from harm. We will share only as much personal data as is necessary and subject to the purposes stated in this Privacy Statement, and will seek your authorized consent again if we share your sensitive personal data or if our affiliates change the purposes for which personal data is used and processed.

(3) Transfers

Transfer with express consent: with your express consent, we will transfer your personal data to other parties; in the event of a merger, acquisition or bankruptcy liquidation of an Dmall service provider, or other circumstances involving a merger, acquisition or bankruptcy liquidation involving the transfer of personal data, we will require the new company, organization or individual holding your personal data to continue to be bound by this Privacy Statement, or we will otherwise, require the company, organization and individual to seek your authorized consent again.

(4) Public disclosure

We will disclose your personal data publicly only if we:

a) disclose your personal data publicly with your express consent or based on your voluntary choice;

(5) Exceptions to prior authorized consent for sharing, transferring, or publicly disclosing personal data

Your prior authorized consent is not required for sharing, transferring, or publicly disclosing your personal data in the following circumstances:

a) when the disclosure is in connection with national security or national defense;

b) when the disclosure is in connection with public safety, public health, or vital public interest;

c) when the disclosure is in connection with judicial or administrative law enforcement, such as crime investigation, prosecution, trial and judgment enforcement;

d) when the disclosure is for the protection of your or other individuals' life, property and other significant legitimate rights and interests but it is difficult to obtain your consent;

e) for personal data that you disclose to the public on your own; and

f) for personal data collected from lawful public disclosures, such as lawful news reports, government information disclosure and other channels.

Please be aware that in accordance with applicable laws and regulations, if we take technical measures and other necessary measures to process personal data, so that the recipient of the data cannot re-identify a specific individual, and that it cannot be recovered, the sharing, transfer and public disclosure of such processed data does not require your consent.

II. How we use Cookies and Similar Technologies

In order to enhance your accessing experience, when you use our Services, we may use various technologies to collect and store information in relation to your access to our Services, which allows us to identify you when you visit or re-visit Dmall Services, and to provide you with better services though analyzing the data. This includes using small files to identify you, store your preferences and save you time by eliminating the need to enter the same information repeatedly. These files could be Cookie, Flash Cookie, or the local storage provided by your browser or application (collectively, “Cookie”).

Please understand that some of our Services can only be implemented through the use of Cookies. If your browser or browser add-on service allows it, you may modify your acceptance of cookies or reject Dmall cookies, which may in some cases prevent you from using some of the features of our Services that rely on Cookies.

III. Legal Basis for Processing Personal Information

Our legal bases for collecting and using your personal data as described in this Privacy Statement fall into one or more of the following four categories.

Consent: Currently, we only collect the minimum necessary information. If you need to withdraw your consent, you need to contact your enterprise user administrator to log out of your account. If you would like to withdraw your consent, you can do so by contacting us as provided in “How to Contact Us.”

Legitimate Interest: We process certain data for the legitimate interests of Dmall, our affiliates, our partners, or our customers. These legitimate interests include, for example, contacting you to provide support; detecting, preventing, and investigating illegal activities and potential security issues; and maintaining and improving the Website and mobile applications. We will rely on our legitimate interests for processing personal data only after balancing our interests and rights against the impact of the processing on individuals.

Performance of a Contract: Sometimes we process personal data to perform our obligations under an agreement with our customer.

Other Legal Bases: In some cases, we may have a legal obligation to process your personal data, such as in response to a court or regulator order. We also may need to process your personal data to protect vital interests, or to exercise, establish, or defend legal claims.

IV. How We Protect your Personal Information

Dmall takes all reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorized access, modification or disclosure.

In particular, we will process your personal data using primarily IT systems and analytical tools through authorized personnel appropriately trained by Dmall. We adopt measures aimed at ensuring the adherence to the principles, including accuracy, lawfulness and transparency, set forth in applicable laws and regulations on the protection of personal data, protecting your privacy through technical and organizational security measures that ensure an adequate level of security to prevent the loss or unlawful or improper use of as well as unauthorized access to your personal data.

V. Data Retention

We will retain your personal data as necessary in connection with the purposes described in this Privacy Statement, for as long as your account is active, and in accordance with Dmall’s retention policies and applicable laws and regulations.

VI.Your Rights Over Your Personal Information

(I) Accessing, Correcting and Supplementing Your Personal Information

You can access, correct or supplement your information through functions within our Services or by contacting us directly.

(II) Deleting Your Personal Information

You may send a request to us for deleting your personal data under the following occasions:

    ● if our collection and use of your personal data violates the applicable laws or regulations;

    ● if we collect or use your personal data without your express consent;

    ● if our use of your personal data was in material breach of your agreement with enterprise user;

    ● if your account is deregistered; and

    ● if we permanently cease to provide Services to the enterprise user that opened a sub-account for you.

Due to the applicable laws and regulations and security measures, after erasure of the relevant data, we may not be able to immediately delete it from system back up. We will securely store your personal data and segregate it from any further processing, until the backup can be erased or anonymized.

(III) Changing the Scope of Your Consent

You can withdraw or change the scope of you consent through means including erasing data or switching off devices.

When you withdraw your consent, we will no longer process the corresponding personal data. However, your decision to withdraw your consent will not affect the previous processing of personal data based on your authorization.

(IV) Deregistration of Your Account

You can deregister your account through functions within our Services or by contacting us directly.

(V) Responding to Your Request

For security, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. We will respond within 15 business days. If you are not satisfied with our response, you can also file a complaint by contacting us.

We in principle do not charge fees with respect to your reasonable requests. However, we may at our discretion charge a fee with respect to repeated or unreasonable requests. While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests or to impose restrictions or requirements upon such requests if required or permitted by applicable law.

VII. Information Relating to Minors

We presume that you have the appropriate civil capacity and that minors should not use our Services in principle. If you are a minor, we request that you ask your parents or other guardians to read this Privacy Statement carefully and to use our Services or provide us with information with the consent of your parents or other guardians.

If we identify you as a minor user, we will promptly notify your guardian to agree to the rules governing the collection and use of personal data from minors. Where we collect personal data from minors with the consent of their parents or other guardians to use our Services, we will only use, share, transfer or disclose such information as permitted by law or regulation, as expressly agreed to by the parents or other guardians, or as necessary to protect the minor.

If you are the parent or other guardian of a minor, please be aware that the minor in your custody is using our Services with your authorized consent. If you have questions about the personal data of a minor in your custody, please contact us through the contact information in “How to Contact Us”.

VIII. International Data Transfers

Dmall may transfer your personal data to its affiliates and/or business partners as permitted by law, if required for the purposes described in this Privacy Statement. This may involve the transfer of your personal data to countries/ regions outside your home country or region which may have a different level of data protection from your home country. Such countries may include, without limitation, Singapore and other countries/ regions in which Dmall’s affiliates and/or business partners maintain facilities.

We will take all reasonable measures to safeguard personal data we transfer.

IX. Changes to this Privacy Statement

This Privacy Statement is subject to change.

We will not limit your rights under this Privacy Statement without your express consent. We will post changes to our Privacy Statement within our Services. We will also provide more prominent notice of material changes (including notice through public posting or even a pop-up notice to you).

Material changes for purposes of this Privacy Statement include, but are not limited to:

a) a material change in our service model. For example, the purpose of processing personal data, the type of personal data processed, the way personal data is processed, etc.;

b) s material changes in our control, etc. For example, changes of information caused by mergers acquisitions or reorganizations, etc.;

c) change in the main target of personal data sharing, transfer or public disclosure;

d) material changes in your rights to participate in the processing of personal data and the way you exercise them;

e) material changes in our department responsible for handling personal data security, contact information and complaint channels; and

f) a personal data security impact assessment report indicates that there is a high risk.

We will also keep the older versions of this Privacy Statement on file for your review.

X. How to Contact Us

If you have any question, opinion or suggestion about this Privacy Statement, please submit your request through jiaojiao.liu@dmall.com.

2302d, 23/F, Cuilin Building, No.10 Kaifeng Road, Meiling Street, Meilin Community, Futian District, Shenzhen, Guangdong Province, China

E-mail: business@dmall.com