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Privacy statement

Privacy Policy for uSmart (Registered Users)

Effective Date: June 10, 2022

uSmart, which is operated by uSmart Securities Limited (hereinafter referred to as “uSmart Securities”) and its partner Yingli Digital Technology (Shenzhen) Co., Ltd. (collectively referred to as “uSmart Group”, “we” or “us”), is a platform of the functions including market data services (including browsing and querying Hong Kong stocks, US stocks and stock quotation) and stock transaction management for users.  We take the security of our users' personal information very seriously and need to collect your personal information due to your use of services and products provided by us, we shall take relevant safety protection measures in accordance with provisions of laws and regulations, so as to try our best commercially reasonable efforts to protect your personal information. For this purpose, this Privacy Policy (hereinafter referred to as this “Policy”) is hereby formulated. We remind you that:

This Policy applies to a variety of products and services of uSmart adopted by you in any manner. Before using any product or service of uSmart, please read over and actually understand this Policy. Don’t use relevant products or services until you have fully understood and agreed on this Policy. Once you start using any product or service of uSmart, it shall be deemed that you have fully understood and agreed on this Policy. Where any product or service of our affiliated companies has made use of any product or service provided by uSmart but fails to formulate any independent privacy policy, this Policy shall also apply to such product or service.

Please read this Policy carefully , as we will explain the types of your personal information collected by us as well as their corresponding purposes, so that you can better understand the types, reasons for use and collection methods of the detailed personal information collected by us for specific function. By clicking "Agree to this Policy" or checking a box with a similar meaning, or by actively logging in, confirming, agreeing, accepting, and using the Mobile Apps and related services provided by us, you agree to our collection, use, storage, sharing, transfer, and disclosure of personal information in accordance with this Policy (including updated versions).  

This Policy will help you understand the following contents:

  1. How we collect your personal information
  2. How we use the information collected by us
  3. How we use Cookie and similar technologies
  4. How we share, transfer or publicly disclose your personal information
  5. How we protect your personal information
  6. How we store the information
  7. Your right to manage your personal information
  8. How we protect information about minors
  9. How your personal information is transferred worldwide
  10. Information that we may send to you
  11. Information shared by you
  12. How we update this Policy
  13. Scope of application of this Policy
  14. How to contact us
  15. How we collect your personal information
  16. In order to provide services to you, maintain normal operation of the products and services of uSmart, improve and optimize our service experience, and safeguard your account security, we will, for the purposes and in the manners stipulated herein, collect the information you provide initiatively and authorize to provide or that is provided based on your requirements when you register/use the products and services of uSmart, as well as that is generated from your use of the services of uSmart.

 (1) When you run or use uSmart, we may obtain the network access to your device.

 (2) When you use your cell phone number and verification code to register with uSmart, we will collect your cell phone number. Cell phone numbers are sensitive, and the reason that we collect such information is to comply with the requirements of the network real name system stipulated by relevant laws and regulations.

 (3) When you log in to uSmart via WeChat, Weibo, Alipay, Apple ID or other third-party accounts, we will obtain your account avatar and nickname in such third-party accounts via third-party authorization services, and save the information to the storage server of uSmart. The information will be used for managing your account for logging in to uSmart. We will not disclose the above-mentioned information to any external party, nor will we use it for any other purpose than this function, unless you choose to do so or comply with the requirements of relevant laws and regulations.

 (4) When you log in to the services without verification code, uSmart will originate the Short Message Service (SMS) of your device. The short message to be sent by you may incur SMS tariff, which will be charged by your mobile network operator. uSmart will not charge any SMS tariff. In case that you refuse to send the short message, you cannot to use the non-verification code login service provided by uSmart; in such case, you can choose to log in with other login methods provided by uSmart.

 (5) When you register, upload certificate, edit your personal information, carry out live video and use other functions of uSmart, if you adopt the "Photo" or “Video” mode under the “Camera” of your device, uSmart will use the Camera permission of your device; if you adopt the "Selecting from Album" mode, uSmart will use the Album permission and the folder read-write permission of your device. In case that you save useful pictures that you find on uSmart to your Album, uSmart will also use the Album permission and the folder read-write permission of your device. The photos and files uploaded by you will be stored in our server, since this function cannot be realized without storage. Besides, uSmart will use the Sound permission of device. The voice message uploaded by you will be stored in our server, since this function cannot be realized without storage.

 (6) When you use the live video, video playback and other similar functions of uSmart, uSmart will use the Floating Window permission, flash lamp and notice of your device, to open/close the permission. If you disagree on the above-mentioned content, you may not be able to play videos, but this will not affect your use of other services of uSmart.

 (7) When you choose to contact the Customer Service via uSmart, we need to use the Calling permission of your device to make a call. If you disagree on the above-mentioned content, you need to directly call the customer service phone of uSmart via your device.

 (8) When you use the reminder function of uSmart quotation system, major event reminder function or other similar functions, uSmart will use the Calendars permission of your device, so that you can obtain relevant information in a timely manner. If you refuse the access, you cannot use the reminder function, but this will not affect your use of other services of uSmart.

 (9) When you carry out internal page interaction (e.g., clicking button) via uSmart, uSmart will use the Vibrate permission of your device. If you fails to accept the above-mentioned content, you will not receive vibration feedback from your device, and this will not affect your use of other services of uSmart.

 (10) For the purpose of guaranteeing you the availability to the notices related to the quotation system and to the services, in a timely manner.

(11) For the purpose of guaranteeing you the normal availability to and use of the rights and services related to quotation, we will carry out validity recognition of territory or account on the IP address, third-party account and avatar, nickname and similar information provided by you. If you disagree on the above-mentioned content, it may influence the validity recognition of territory or account, thus influencing the rights and services related to quotation to be available to and used by you.

 (12) When you access the account opening function of a broker via uSmart, uSmart will use the Camera permission and Sound permission of your device; if your refuse to offer the Camera permission and Sound permission, you cannot normally complete the account opening procedure. As required by brokers and applicable laws, when you apply to open an account via uSmart, you must submit the photo of the front and back of your ID certificate, your bareheaded photo, your mailing address, the organization where you work, your occupation and position, and other similar information. If you disagree on the above-mentioned content, you cannot open an account, but this will not affect your use of other services of uSmart.

 (13)When you access the account opening function of a broker via uSmart, uSmart will use the NFC read-write permission of your device to read the NFC anti-counterfeit label of your device. If you refuse to offer the NFC read-write permission, you cannot normally complete the account opening procedure.

 (14)During its operation, uSmart will read IMEI, MAC address and Android ID, for the purpose of helping us confirm that your device is unique and guaranteeing the data security of uSmart.

 (15)When you share pictures or URLs to any other third-party Apps (e.g., WeChat, QQ, Alipay, and etc.) via uSmart, uSmart will read the list of your APPs to confirm whether the target third-party App with which you intend to share have been installed in your device.

 (16) When you use uSmart, in order to allow you to use our services normally and to improve and optimize our service experience, and to guarantee the security of your account, we will collect information related to both the services you use and your usage mode, and correlate the information. Such information includes:

  1. Log information: When you use products or services provided by our website or APP, we will automatically collect your detailed use of our services and will save such information as relevant weblogs, e.g., your login account, search/enquiry content, IP address, browser type, telecom operator, network environment, language used by you, date and time of webpage view and your web browsing history, records of Push, duration, records of refresh, records of posting, your following and your sharing.We will obtain the storage permission of your device to saving the aforementioned log information.
  2. . Device information: We will, based on the specific permissions you grant during the installation and use of the software, receive and record the information related to the device used by you (e.g., IMEI, MAC, Serial, IMSI of SIM card, device model, operating system and its version, the client version, resolution of your device, package name, settings of your device, the unique device identifier, features of software and hardware); and the information related to the location of your device (e.g., IP address, GPS location, WLAN access point that can provide relevant information, and information related to Bluetooth and base station sensor).

 (17)When you upgrade your uSmart APP, we will use the Application Installation permission of your device. For the purpose of guaranteeing normal upgrading, we will also use the Installation Channel Tracking permission of your device. If you disagree on the above-mentioned content, you cannot upgrade your APP; in such case, you may not be able to use the updated function of the APP or the updated service of uSmart, and you may not be able to normally use your uSmart APP.

  1. Please understand that we will update and improve the functions and services provided by us to you, from time to time. If certain function or service that is not listed in the foregoing clause has collected your information, we will explain the content, scope and purpose of such information collection to you separately, in the manner of page prompts, interactive processes, website announcements, and etc.
  2. We may obtain relevant information that you have authorized for sharing from related parties or third-party partners. We will collect and use such information in accordance with the provisions of relevant laws and regulations, and the agreements between us and the related parties or third-party partners, provided that such information provided by them is from legitimate sources.

4 The above-mentioned information provided by you may contain sensitive personal information, e.g., your bank account No., your transaction records, information about your virtual property, your system account No., your email addresses and their passwords, your phone number, your web browsing history, and your locational information. Please pay attention to such sensitive personal information. You agree that we may process your sensitive personal information for the purposes and in the manners stipulated in this Policy.

  1. How we use the information collected by us

For the purpose of providing services to you, improving service quality and providing safe, smooth and efficient experience to you, we will use your authorized personal information to implement the functions of the APP based on the intents and purposes set forth in this Policy for the following purposes, under the premise of strictly complying with the provisions of laws and regulations, this Policy and other agreements between you and us:

  1. Providing a variety of relevant services to you;
  2. Giving us an idea of how you access and use relevant services, so as to optimize our methods of providing service to you;
  3. Optimizing our development and services, e.g., in case that a fault occurs to our system, we will record and analyze the information generated from such system fault, so as to optimize our services;
  4. Sending you marketing information (optional to turn off by: Settings—Notification Settings--Promotional Message Settings—choose “Close”) for promoting services of uSmart, as well as products and services of third parties; recommending you the information and news in which you are interested; and sending you notices related to services of uSmart;
  5. Evaluating and improving our promotional effectiveness;
  6. Managing software, e.g., software certification and software upgrading;
  7. Inviting you to participate in surveys related to our services;
  8. For the purpose of preventing, detecting and investigating fraud, infringement, safety hazards, illegal or violations of agreements, policies or rules of us or with our affiliated companies, to protect the legitimate rights and interests of you, other users, the public, our Company or our affiliated companies, we will use or integrate your personal information, information about service usage, equipment information, log information, the information for which our affiliated companies and partners have obtained your authorization, and the information shared according to law, so as to comprehensively judge your account risk and transaction exposure, to carry out identity authentication, to detect and prevent security incidents, and to take necessary measures, e.g., recording, audit, analysis and disposal;
  9. For the purpose of ensuring the security of the services and helping us better understand our APP’s running condition, we may record relevant information, e.g., the frequency of your use of the APP, crash data, overall use condition, performance data, and source of the APP. However, we will not combine the information we store in our analytics software with your personal identity information provided by you in the APP;
  10. Please note that if you provide information that contains personal information of another person, you need to ensure that you have the legal authorization of that person before providing such personal information to us.
  11. Other purposes authorized by you.

If we use your personal information for any purpose other than that we state upon collection or beyond the directly or reasonably related scope, we will, before using your personal information, notify you again and obtain explicit consent from you.

In addition, we may, without obtaining your authorization or consent, collect and use your personal information in any of the following conditions in accordance with relevant laws, regulations and national standards:

 (1) Where the personal information is related to the fulfillment of laws, regulations and supervisory rules;

 (2) Where the personal information is related to national security, national defense security or other national interests;

 (3) Where the personal information is related to public security, public health, public right to know, or other major public interests;

 (4) Where the personal information is directly related to criminal investigation, prosecution, justice, and execution of judgment, and etc.;

 (5) For the purpose of safeguarding your or other individuals’ legitimate rights and interests (e.g., life, property, reputation), but it’s difficult to obtain your consent;

 (6) The personal information disclosed by you to the public;

 (7) The personal information collected from the source of legally and publicly disclosed information, e.g., legal news coverage, government information publicity;

 (8) Where the personal information is necessary for signing and performing the contract, as required by you;

 (9) Where the personal information is necessary for maintaining the safe and stable operation of the products or services provided by us, e.g., finding or handling faults of the products or services;

 (10) Where the personal information is necessary for legal news coverage;

 (11) Where the personal information is necessary for carrying out statistics or academic research for the purpose of public advantages, and before providing result of such academic research or describing the result to external parties, the de-identification treatment has been done for the personal information contained in the result; and

 (12) Other conditions stipulated by laws and regulations.

You acknowledge and agree that after collecting personal information, we may de-identify the information through technical means, and the de-identified information will not identify you personally, in which case we may use the de-identified information to analyze and commercially exploit the database without obtaining your consent. All personal information provided by you when using the Mobile Apps will continue to be authorized for our use unless you delete it or refuse to allow us to continue collecting it through your device's system settings.

 

III. How we use Cookie

In order to offer you easier access experience, when you use products or services of uSmart, we may collect and store your data related to your access to uSmart, by a variety of technologies, so that when you access or re-access uSmart, we could identify you and offer you better and more services based on data analysis, including identifying you through small-scale data files. We collect such data to understand how users use our services, so that users will not be required to re-type their account information and we can determine whether your account is secure. These data files may be Cookies, Flash Cookies, or other local storage provided by your browser or related applications (collectively referred to as "Cookies"). We will not use Cookies for any purpose not stated in this Policy. You can manage or delete Cookies based on your own preferences. For details, please visit AboutCookies.org. You can delete all the Cookies stored on your computer, and most web browsers provide the option of blocking Cookies. However, by doing so, you may not be able to use the functions of uSmart that rely on Cookies in some cases, and you have to change the user settings every time you visit our website.

  1. How we share, transfer or publicly disclose your personal information
  2. Share

Except any of the following cases, we will not share your personal information with any company, organization or individual other than the service supplier of uSmart:

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

 (2) Sharing your personal information under legal circumstances: We may share your personal information as required by laws and regulations, or according to lawsuit/dispute resolution or legal requirements by administrative agencies or judiciary authorities.

 (3) It’s necessary to share your data (e.g., your IDFA, network identity identifier. IP address, IMEI, MAC address or other relevant information), so that we can provide the third-party products and services required by you, or carry out data analysis or research for uSmart, or improve our products and services. At present, third-party SDK services that we access mainly include the following types:

  • Providing IM message communication function;
  • Providing free-flow services;
  • Report and analysis of user behavior data;
  • Providing payment service;
  • Report of APP crash;
    ● Performance statistics;
    ● Providing live-streaming supporting function;
  • Providing services related to browsers;
  • For advertising statistics and monitoring;
  • For login by third-party account;
  • For sharing contents of uSmart on third-party platforms by you.

Relevant parties are in charge of operation of these third-party services, which shall be subject to the service terms and message protection statement of such third parties (not this Privacy Policy). To obtain an understanding of device permission types called by such third-party SDK, and how your personal information is collected and used, it’s suggested that you shall refer to relevant service agreement and privacy policy of third-party SDK. For further information related to the third-party SDK that we access, please refer to the Third-party SDK List of uSmart.

 (4) If you are complained by others or you complain others, we will submit the information related to such complaints, e.g., your identity information to relevant supervisory authorities, for solving such complaints or disputes, unless expressly prohibited by laws and regulations.

 (5) Exchanging information with other companies and organizations for the purpose of complying with laws, executing or applying the conditions of use of our services or other agreements, preventing fraud or other illegal activities, or reducing credit risk.

 (6) Sharing your personal information with our affiliated companies: We may share your personal information with the affiliated companies of uSmart Group. We will only share necessary personal information, and will be bounded by the purposes stated in this Policy. Where any of our affiliated companies intends to modify the processing intent of your personal information, it will re-ask for your authorization and consent. Our affiliated companies include but are not limited to uSmart Securities Limited, Yingli Digital Technology (Shenzhen) Co., Ltd. and Shenzhen Yingli Intelligent Service Co., Ltd.

 (7) Sharing with the partners authorized by us: Only for the purpose of fulfilling the purposes stated in this Policy will some of our services be provided by the partners authorized by us. We may share some of your personal information with such partners, so as to provide better customer services and user experiences to you. For example, when you participate in any rewards event provided by us, for the reason of granting rewards or arranging our partners to provide services to you, we must share your personal information with the partners. We will only share your personal information for legal, proper, necessary, special and explicit purposes, and will only share the personal information required for providing the services to you. Our partners shall have no right to use the personal information shared by us for any other purpose.

 (8) Sharing with third parties in accordance with the Registration Agreement of this software or relevant provisions between you and us.

 (9) Other provisions related to information sharing between you and us.

We will sign strict confidentiality agreements with the companies, organizations and individuals with whom we share personal information, requesting them to process personal information according to our instructions, this Policy or any other relevant measures related to confidentiality and security.

  1. Transfer

Except any of the following cases, we will not actively transfer your personal information:

 (1) Where the relevant operations have been explicitly agreed by you in advance;

 (2) In case of merger, acquisition or bankruptcy liquidation that involves personal information transfer, we will request the new companies and organizations that hold your personal information to be bounded by this Privacy Policy; otherwise, we will request such companies and organizations to re-ask for your authorization and consent.

 (3) Other conditions that require the transfer of your personal information pursuant to provisions of laws and regulations or requirements of competent authorities.

  1. Public disclosure

We will only publicly disclose your personal information in the following cases:

 (1) After obtaining your explicit consent;

 (2) Public disclosure based on laws: As required by laws, legal procedures, lawsuits or under mandatory requirements of government authorities, we may publicly disclose your personal information;

(3) If we confirm that you have violated laws or regulations or have seriously violated relevant protocol rules of uSmart, or for the purpose of protecting the property safety and personal safety of users of uSmart Group (and its affiliated companies) as well as the public against personal injuries or property damages, we may, with obtaining consent from you, disclose your personal information according to laws or regulations or relevant protocol rules of uSmart, including relevant illegal behaviors and measures that uSmart has taken on you.

  1. Exception of obtaining authorization and consent in advance for sharing, transferring or publicly disclosing personal information

(1) Where the personal information is related to the fulfillment of laws, regulations and supervisory rules;

(2) Where the personal information is related to national security or national defense security;

(3) Where the personal information is related to public security, public health or major public interests;

(4) Where the personal information is related to criminal investigation, prosecution, justice, and execution of judgment, and etc.;

(5) For the purpose of safeguarding your or other individuals’ legitimate rights and interests (e.g., life and property), but it’s difficult to obtain your consent;

(6) The personal information disclosed by you to the public;

(7) The personal information collected from the source of legally and publicly disclosed information, e.g., legal news coverage, government information publicity;

(8) Please be noted that sharing and transfer of anonymous personal information in accordance with the laws does not belong to external sharing, transfer or public disclosure of personal information, provided that the receiving party cannot recover such personal information nor re-identify subjects of such personal information. We will not further notify you of the storage or processing of such anonymous data, nor will we obtain your consent for the same.

  1. How we protect your personal information

We will take a variety of precautions to safeguard your personal information against loss, theft and misuse and unauthorized access, disclosure, alteration and destruction. To protect your personal information, we have formulated strict information security regulations and processes, and our special information security team will strictly implement the foregoing measures within our Company.

We will take reasonable and practicable measures to guarantee that no irrelevant personal information will be collected. We will retain your personal information for no longer than the period that is necessary for the purposes stated in this Policy, unless the extension of the retention period is required or permitted by law.

The Internet is not absolutely secure, and your emails, instant messaging tools and your exchange with other users of uSmart are unencrypted, so we strongly suggest you shall not send any personal information in any of such ways.

We will establish emergency response plans; in case of any security incident, e.g., personal information leakage, we will activate the emergency response plans, to prevent such security incident from spreading. We will inform you of the information related to such incident by email, mail, phone call, push notification and etc. in a timely manner. In case that it is difficult to inform each personal information agent, we will take reasonable and effective measures to release announcements. The Internet is not 100% secure. In spite of these security measures, please be noted that there is no "perfect security measure" on the Internet, but we will try our best to ensure the security of your information.

  1. How we store the information
  2. In accordance with provisions of the laws and regulations, we shall store your personal information that we collect withintheterritory of the People's Republic of China (hereinafter referred to as “China”) and shall keep such information strictly confidential. Where the personal information of relevant users collected by us within the territory of China needs to be transmitted to any overseas agency in certain situations, we shall execute it in accordance with the provisions of the laws, administrative regulations and supervision departments, and shall request such overseas agency to keep your personal information confidential, by signing agreements, on-site verification or other effective measures.
  3. Generally, we will retain your personal information for no longer than is necessary for the purposes stated in this Policy. However, in any of the following conditions, we may change the storage time of your personal information for complying with legal requirements:

(1) To abide by relevant provisions of applicable laws and regulations;

(2) To abide by the provisions of court decision, ruling or other legal procedures;

(3) To abide by requirements by relevant government agencies or organizations of legal authorization;

(4) Purposes reasonably necessary for fulfilling relevant service agreements or this Policy, protecting social and public interests, protecting personal and property safety or other legitimate interests of our customers, our Company or our affiliated companies, other users or our employees.

VII. Your right to manage your personal information

  1. During the period in which you use the services of uSmart, in order to allow you to access, modify and delete your personal information more conveniently, and to guarantee your rights to withdraw your consent to use your personal information and rights to close your account, we provide you the following operation setups in our product design, including but not limited to:

(1) Accessing your account information. If you hope to access or edit personal information in your account, change your password, add security information or close your account, you can perform the operation by accessing [uSmart - Settings - Account & Security]; meanwhile, you can access or view your search history at the search box of uSmart; and

(2) Modifying your personal information. You can also perform the operation by accessing [uSmart - User Account Avatar - Settings – Personal Information].

(3) Close account:

  1. If you have registered a uSmart account but have not accessed the account opening function of a broker or the account opening function is in processing, you can close your uSmart account by accessing the [uSmart - User Account Avatar - Settings – Account & Security – Delete Account]. After the operation is completed, your uSmart account will be closed with immediate effect;
  2. If you have registered a uSmart account and accessed the account opening function of a broker, you can close your uSmart account with the help of the customer service by accessing the [uSmart - User Account Avatar – Help Center – Contact Us] or by contact us at cs@usmarthk.com. Our customer service will assist to close your uSmart account within 5 working days.

After you close your account, we will retain your relevant information in accordance with the Securities and Futures Ordinance (Chapter 571 of the Laws of Hong Kong) and relevant laws and regulations. Your personal information will be deleted or anonymized after the legal retention period has expired. If you wish to continue to use the services of uSmart, you will need to re-register a uSmart account.

(4) Reporting community comments. If you think the comments in U Market community may involve illegal information such as fraud or other situations that need to be reported, you can close the comments by clicking the Report function of the button in the upper right corner of the comments. Please note that after you close your account, delete the data of the application, or uninstall and reinstall the application, the above operations will not be retained.

  1. Where you find out that our collection or use of your personal information violates any law, administrative regulation or provisionsbetween you and us, you may contact us at cs@usmarthk.com, to request us to delete the personal information collected under such violation.
  2. Where you find out that there is any inaccuracy in your personal information collected or stored by us, you may contact us at cs@usmarthk.com, to request us to modify such inaccuracy in a timely manner.

VIII. How we protect information about minors

We attach great importance to the protection of minors’ personal information. In accordance with the provisions of relevant laws and regulations, if you are a minor under 18 years old, it’s suggested that you shall not submit any of your personal information until your parent or guardian has read over this Policy and they have agreed on such submission. Meanwhile, it’s suggested that you shall use our service under your parent’s or guardian’s guidance; otherwise, you must stop submitting any information immediately and notify us as soon as possible, so that we can take effective measures. In addition, we will only use or disclose information about minors to the extent permitted by the laws and regulations, with express consent of your parent or guardian, and as necessary for protecting your interests. If you are parent or guardian of a minor, in case that you have any question related to the personal information of the minor in your guardianship, please contact us according to the contact information stipulated in the first page or Article XIV of this Policy.

  1. I How your personal information is transferred worldwide

(1) In principle, the personal information collected and generated by us within the territory of China will be stored within the territory of China. Since we provide products or services through the resources and servers around the world, it means that your personal information may be transferred to or be accessed by jurisdictions outside of the country/region where you use such products or services after we obtain your authorization and consent. If we subsequently need to transfer your personal information collected and processed under this Policy to other countries for business or administrative purposes (including making your personal information accessible to other jurisdictions), we will meet the necessary pre-requisites and fulfill the corresponding legal obligations in strict compliance with laws and regulations and requirements of regulatory authorities before such transfer, including informing you of the name and contact details of the foreign recipient, the purpose and manner of the transfer, the type of personal information to be transferred, the manner and procedure by which you can exercise your rights with the foreign recipient and obtaining your separate consent. Such jurisdictions may enforce different data protection laws, or even have not formulated any relevant law; in such cases, we state and ensure that your personal information is entitled to equal protection within the territory of China, e.g., we may request for your consent to transfer of your personal information across boundaries or implement the security measures such as data de-identification, prior to transfer of your personal information across boundaries.

(2) If you visit the service platforms and pages of international brokers or third parties to obtain their products or services, the international brokers or third parties may provide their products or services through resources and servers around the world. If you wish to obtain such products or services, you may need to provide the relevant information directly to the international brokers or third parties located outside of China according to the demand for the relevant products or services. Please refer to the relevant parts of this Policy to determine your own risk and decide whether to accept, use or provide information to international brokers or third parties in relation to such products or services.

 

  1. Information that we may send to you
  2. When you use our services, we may send you emails, SMSs, messages or push notifications. You may unsubscribe them on your device according to relevant instructions made by us.
  3. If necessary (e.g., when certain service is suspended for the reason of system maintenance), we may send you announcements related to our services. You may not be able to cancel such non-advertising announcements related to services.
  4. Information shared by you

You could share the information (e.g., texts and photos you share publicly in the Discussion Zone of uSmart) related to you with your friends, your families and other users, via our services. You could control the extent of the information to be shared by you, through the Privacy Settings in our services, or you could delete the information that you have shared publicly, through the Settings in our services or according to our guidance. However, please be noted that the information shared by you may be independently saved by other users or non-related third parties not under our control.

XII. How we update this Policy

We will update this Policy in a timely manner, as required by relevant laws and regulations, in case of change in our businesses or under other necessary situations. Without your explicit consent, we will not reduce any of your rights to which you are entitled in accordance with this Policy. We will announce any modification to be made by us to this Policy on this page, and notify you of the updated policy by releasing it on our official website or in any other proper way for you to receive notices. In such case, your continued use of our services shall be deemed that you agree to be bound by the revised and updated policy.

XIII. Scope of application of this Policy

  1. Except our expressly stated services to which other separate privacy policies or clauses specially formulated by us apply, this Policy shall be applicable to any and all services provided by all companies under the control of uSmart Group to you. However, where we have formulated special privacy policy for certain service as needed, and there is any conflict between this Privacy Policy and the privacy policy of such certain service, the later shall prevail.
  2. Headings of all clauses herein shall be for convenience only, without any actual connotation, which cannot be used as basis for interpreting this Policy.

XIV. How to contact us

If you have any question, comment or suggestion on this Policy or our data processing, please contact us by sending email to cs@usmarthk.com, or by sending mail to us at the following address:

Yingli Digital Technology (Shenzhen) Co., Ltd.
uSMART Marketing Department

Address: Room 1002, 10/F, Unit4, Building B, Kexing Science Park, No.15 Keyuan Road, Science Park Community, Nanshan District, Shenzhen

Post code: 518000

 

Or

uSmart Securities Limited
Customer Service Department
Address: Unit 2606, 26/F, FWD Financial Centre, 308 Des Voeux Road, Sheung Wan, Hong Kong