GOGOSUNNY Consumer Business Privacy Statement
The GOGOSUNNY Consumer Business Privacy Statement was updated on April 25, 2019.
SHENZHEN GOGOSUNNY ELECTRONICS TECHNOLOGY CO., LTD. and its global affiliates (collectively, " GOGOSUNNY ", "we", "us", and "our") respect your privacy. Therefore, we have developed a Privacy Statement (hereinafter referred to as "this Statement") that covers how we collect, use, disclose, protect, store and transfer your personal data. Please take a moment to read and understand our privacy statement and let us know if you have any questions.
Personal data means any electronic or other information which alone or jointly with other information can be used to identify a natural person or make him/her identifiable. This Statement explains how GOGOSUNNY processes your personal data, but does not cover all processing scenarios as you will be informed in specific processing activity. Therefore, before using a specific product or service, it is recommended that you read the privacy notice or supplementary statement released by GOGOSUNNY for that product or service to understand how it processes your personal data.
This Statement applies only to GOGOSUNNY car multimedia entertainment player system.
I. How GOGOSUNNY Collects and Uses Your Personal Data
A. Personal Data Collected by GOGOSUNNY
Before using GOGOSUNNY products or services, you may need to provide personal data. You do not have to provide your personal data to GOGOSUNNY, but in some cases, the non-provision of certain personal data will cause the inability to provide you with some related products or services.
GOGOSUNNY will collect and use your personal data for the purposes stated in this Statement. Here are some examples of personal data we may collect:
1. Personal data that you provide to GOGOSUNNY
We may ask you to provide relevant personal data, such as your name, mobile number, etc.
GOGOSUNNY will take appropriate and necessary measures to ensure the security of the information that you provide.
2. Information that GOGOSUNNY collects in your use of services
GOGOSUNNY will collect data about your device and how you and your device exchange information with GOGOSUNNY products and services. This type of information includes:
(1) Device and application information, such as the device name, device identification code, device activation time, hardware model, OS version, application version, software identification code, and device and application settings (such as region, language, time zone, and font size).
(2) Location information. GOGOSUNNY will collect, use, and process the approximate or precise location of your device when you access some location-based services (for example, when you search, use navigation software, or view the weather of a specific location). Location information can be obtained based on the GPS, WLAN, and service provider network ID. We will ask you to choose the applications for which you want to enable location services. In the device settings menu, you can disable the location permissions of specific services to reject sharing your location information.
B. How GOGOSUNNY Uses Your Personal Data
GOGOSUNNY may use your personal data for the following purposes:
(1) Send you OS or application updates and installation notifications.
(2) Provide personalised user experience and content.
(3) Synchronise, share, and store the data you have uploaded or downloaded, as well as the data needed for the upload and download operations.
(4) Improve our loss prevention and anti-fraud programmes.
(5) Other purposes within specific services or with your consent.
II. How GOGOSUNNY Entrusts, Shares, Transfers, and Discloses Your Personal Data
A Entrusting other parties
In some cases, GOGOSUNNY may entrust other companies to process your personal data on behalf of GOGOSUNNY. For example, GOGOSUNNY may entrust another company for hotline support, sending emails, and providing technical support. Such companies may only use your personal data to provide services to you on behalf of GOGOSUNNY.
GOGOSUNNY will enter into a strict non-disclosure agreement or personal data processing terms with the entrusted party to require them to process your personal data in accordance with this Statement and by taking relevant confidentiality and security measures.
Sharing refers to the process in which GOGOSUNNY provides your personal data to other personal data controllers, and both parties have independent control over your personal data. GOGOSUNNY will not share your personal data, except in the following situations:
1.Sharing with explicit consent: After obtaining your explicit consent, GOGOSUNNY will share the information within the scope of your authorization with a designated third party.
2.Sharing under statutory circumstances: GOGOSUNNY may share your personal data in accordance with laws and regulations, the demands of dispute resolution, or according to the legal requirements of administrative and judicial authorities.
3.Sharing with GOGOSUNNY 's business partners: To ensure the quality of services provided to you, GOGOSUNNY may share your order, account, device, and location information with our third-party partners. However, we will only share your personal data for legal, appropriate, necessary, specific, and clear purposes. We will only share personal data that is necessary for providing these services. Our partners include:
(1) Third-party sellers and developers: Some of our products and services are provided directly to you by third parties. In this case, GOGOSUNNY will share transaction-related information with third parties to fulfill the requirements for the goods or services you have purchased. For example, when you purchase products from third-party developers in GOGOSUNNY AppGallery, we will share the necessary information with the developer to complete the transaction.
(2) Providers of goods or technical services: GOGOSUNNY may share your personal data to third parties that support our features and functions, including third parties that supply or provide infrastructure technology services, logistics and distribution services, payment services, and data processing services. We share this information for the purpose of implementing the functionality of our products and services. For example, we will share your order information with the logistics service provider to arrange delivery, or your order number and purchase amount with a third-party payment agency to confirm your payment instructions and complete the transaction.
GOGOSUNNY will enter into a strict confidentiality agreement with companies, organizations, and/or individuals, requiring them to abide by this Statement and take appropriate confidentiality and security measures when processing your personal data.
A transfer refers to the process of transferring control of personal data from GOGOSUNNY to another personal data controller. GOGOSUNNY will not transfer your personal data to any company, organization, or individual, except in the following situations:
1.Transferring with explicit consent: After obtaining your explicit consent, GOGOSUNNY will transfer your personal data to other parties;
2.Mergers, acquisitions, or liquidation: When the transfer of your personal data is involved due to merges, acquisitions, or liquidation, GOGOSUNNY will request new companies and organizations that hold your personal data to continue to abide by this Statement. Otherwise, GOGOSUNNY will request that the company or organization to seek out your authorization again.
D Public Disclosure
GOGOSUNNY will only disclose your information to the public in the following situations:
1.After obtaining your explicit consent;
2.Public disclosure in accordance with laws or reasonable grounds: GOGOSUNNY may disclose your information publicly when required by law, legal process, litigation, or public and government authorities.
III.How GOGOSUNNY Protects Your Personal Data
GOGOSUNNY attaches significant importance to the security of your personal data and has adopted standard industry practices to protect it from unauthorized access, disclosure, use, modification, damage, or loss. To this end, GOGOSUNNY has taken the following measures:
1.We take all reasonable and feasible measures to ensure that the personal data collected is minimal and relevant to what is necessary in relation to the purposes for which they are processed. We retain your personal data for no longer than what is necessary for the purposes stated in this Statement and in the privacy notice of a specific product or service, unless an extension of retention period is required or permitted by law.
2.We use a range of technologies such as cryptographic technologies to ensure the confidentiality of data transmission and storage, and implement trusted protection mechanisms to protect data and data storage servers from attacks.
3.We deploy access control mechanisms to ensure that only authorized personnel can access your personal data. In addition, we control the number of authorized personnel and implement hierarchical permission management on them based on service requirements and personnel levels. Access to personal data will be logged and reviewed by authorized personnel on a regular basis.
4.We carefully select business partners and service providers and incorporate personal data protection requirements into commercial contracts, audits, and appraisal activities.
5.We hold security and privacy protection training courses, tests, and publicity activities to raise employees' personal data protection awareness.
GOGOSUNNY is committed to protecting your personal data. Nevertheless, no security measure is perfect and no product, service, website, data transfer, computing system, or network connection is absolutely secure.
In response to possible risks, such as personal data leakage, damage, and loss, GOGOSUNNY has developed several mechanisms and control measures, clearly defined the rating standards of security incidents and vulnerabilities and corresponding processing procedures, and established a dedicated Security Advisory and Security Notice page. GOGOSUNNY has established a dedicated emergency response team to implement security planning, loss reduction, analysis, locating, and remediation, and to perform tracking operations with related departments based on security incident handling regulations and requirements.
In the event of a personal data security incident, GOGOSUNNY will notify you, pursuant to relevant legal and regulatory requirements, of the basic information about the security incident and its possible impact, measures that GOGOSUNNY has taken or will take suggestions about active defense and risk mitigation, and remedial measures. The notification may take the form of an email, text message, push notification, etc. When it is difficult to inform data subjects individually, we will take appropriate and effective measures to release a Security Notice. In addition, we will also report the handling status of personal data security incidents as required by supervisory authorities.
Ⅳ.How You Can Manage Your Personal Data
A Access, rectification, and deletion
Legislation in some countries and regions to which GOGOSUNNY provides products and services stipulates that data subjects have the right to access, rectify, or delete related personal data retained by GOGOSUNNY. In such countries and regions, data subjects or their agents may make requests (hereinafter referred to as "requests") to access, rectify, or delete relevant personal data retained by GOGOSUNNY.
1.Requesting methods and channels
Data subjects' requests must be submitted in writing. The requests are equally valid even if the requester does not specify the laws on which the requests are based. In general, verbal requests are not valid; however, if the legislation of some countries admits verbal requests, then GOGOSUNNY will abide by such legislation.
Data subjects' requests may be initiated through the official website of GOGOSUNNY Consumer BG, HiCare app. If a data subject initiates a request via a hotline, email, online customer service, service center, or another channel, we will instruct the data subject to officially raise the request through one of the aforementioned channels to facilitate communication and feedback of progress and results. The dedicated request channels for data subjects are intended to protect data subjects' lawful interests, ensure GOGOSUNNY 's normal operation, and prevent the right to request from being misused or fraudulently used.
2.Validity of requests
Most laws require data subjects to comply with specific requirements upon initiating requests. This Statement requires data subjects to:
(1)Submit requests through dedicated request channels provided by GOGOSUNNY (namely, the official website of GOGOSUNNY Consumer BG, HiCare app).
(2) Provide sufficient information for GOGOSUNNY to verify their identities (to ensure those who initiate the requests are the data subjects themselves or those authorized by them).
(3) Ensure that their requests are specific and feasible.
3.Request processing period
GOGOSUNNY shall endeavor to respond within one month of receiving a request to access personal information. Depending on the number of requests and their complexity, this period may be extended to two months if necessary. If the request period is extended, GOGOSUNNY shall notify the data subject of the situation and reason for delay. If the time period stipulated in this section conflicts with local laws and regulations, local laws and regulations shall prevail.
After the request is submitted, the following may occur:
(1) Request may be declined
Requests from data subjects may be declined in the following situations, including but not limited to:
a.Local law does not grant these rights to the personal data subject;
b.The identity of the requester cannot be verified;
c.The request cannot be verified or exceeds the scope, especially when requests are sent repeatedly;
d.If the information involved is related to the compensation that GOGOSUNNY will make or receive as a result of an ongoing dispute, and the disclosure of such information is likely to damage GOGOSUNNY 's interests;
e.If the retained information is being used for statistical and research purposes only, and the publication of statistics and research results does not reveal personal identities;
f.Other legal provisions.
If GOGOSUNNY declines a request from a data subject, it will provide the requester with a formal explanation.
(2) Request may be approved
If the scenarios listed in the previous section (1) do not occur, GOGOSUNNY will meet the request of the data subject. In order to improve the approval rate of your request, please provide as much detailed information as possible when submitting your request, such as the request type, specific information, information about the data subject (such as the account name you use for GOGOSUNNY products and services), and the time frame in which the information was generated or processed. Requests within a shorter period of time have a higher likelihood of success.
5. Special note
(1) Only legal guardians or legally authorized persons have the right to access the personal information of others.
(2) Most legal provisions clarify situations when organizations are not required to provide information to data subjects. Situations include scenarios when providing data may undermine ongoing efforts against terrorism, when the data subject has made repeated requests, or when obtaining and providing such information shall consume disproportionate resources.
(3) In principle, GOGOSUNNY will not provide the following types of information:
a.Information about others: Requests from data subjects may involve other individuals besides the data subject. Unless authorized by the relevant individuals, GOGOSUNNY shall not provide such information.
b.Repeat requests: If the data subject makes multiple requests of the same type related to the same data subject, and the data has not changed since the last time GOGOSUNNY provided the data, GOGOSUNNY will not usually provide a copy of the data. Additionally, GOGOSUNNY does not have a responsibility to provide to individuals any data that has already been made public.
c.Confidential opinions: If the requested information related to the data subject is a confidential opinion, GOGOSUNNY does not have a responsibility to provide such information.
d.Special documents: GOGOSUNNY will not disclose any special information in response to requests for accessing personal information. Typically, special information includes any confidential documents such as attorney/client communication, or information that obtains or expresses a corresponding legal opinion, whether it is related to the lawsuit itself or related to information from court proceedings.
B Withdrawal of Authorization
You can withdraw or modify your authorization to continue collecting your personal information by deleting data, disabling device features, and modifying the privacy settings on your GOGOSUNNY device or app. You can also withdraw your authorization to collect your personal information during operations related to your GOGOSUNNY account by deactivating your account.
Please note that the implementation of each operation and function requires some basic personal data. When you withdraw your authorization, we will no longer provide you with corresponding services, nor process your corresponding personal data. However, your decision to withdraw your consent or authorization will not affect the processing of your personal data based on your previous authorization.
How to withdraw your consent or authorization for a specific product or service is detailed in the Privacy Statement and supplementary statement attached to that product or service.
Ⅴ Updates to This Statement
GOGOSUNNY reserves the right to update this Statement at any time.
Should this Statement be revised from time to time, GOGOSUNNY will release the change notice via various channels, such as posting the latest version on its official website: (http:// www.gogosunny.com/smartlink/privacy_policy). GOGOSUNNY will also send you an individual notice of the update (e.g. electronic notice) to notify you of any changes to this Statement, and will provide a clear and obvious notice (e.g. in the form of a public notice on the official GOGOSUNNY website or in the form of a pop-up) of any major changes to this Statement.
"Major changes" in this Statement include but are not limited to:
1.Major changes in our service modes, for example, purposes of personal data processing, types of processed personal data, and ways of using personal data.
2.Major changes in our ownership structure, organizational structure, etc., for example, ownership changes caused by business adjustment, bankruptcy, or acquisition.
3.Changes in the main objects of personal data sharing, transfer, or disclosure.
4.Major changes in your rights regarding personal data processing and the ways in which you can enjoy those rights.
5.Changes of GOGOSUNNY departments, contacts, and complaint channels responsible for the security of personal data processing.
6.High risks identified in assessment reports of personal data security impact.
Ⅵ How to Contact Us
If you have any questions, comments, or suggestions, please contact us by visiting the contact us page or all our hotline: +86-755-29995963-801.
Note: Due to differences in local laws and languages, the local versions of GOGOSUNNY Consumer Business Privacy Statement may be different from this version. In case of any conflicts, the local versions shall prevail.
Copyright © 2019 SHENZHEN GOGOSUNNY ELECTRONICS TECHNOLOGY CO., LTD. All rights reserved.
Last updated: April 25, 2019