The Policy explains the following:
- How we collect and use your personal information
- Purposes for collecting your personal information
- Legal bases for collecting your personal information
- How we share, transfer or make available your personal information
- How we protect your personal information
- Personal information preservation and retention
- How to manage your personal information and your rights
- Protection of minors’ information
- Notices and amendments
- How to contact us
The Policy is closely related to services made available to you by Paudi Model and various business functions included in the foregoing services (“our products and/or services”). Before using our products and/or services, you are kindly advised to read the Policy carefully and ensure that you fully understand it. The Policy tries to apply clear and concise terminology and provides links to further explanations for your better understanding.
If you have any questions about the Policy or related issues, you can at any time email us at email@example.com or contact us otherwise.
- How we collect and use your personal information
Personal information refers to various information that is recorded electronically or otherwise and can be used alone or in combination with other information to identify a specific natural person or reflect the activities of such a person.
The personal information that we collect will include:
- basic information (including name, date of birth, gender, address, personal phone number, email address);
- identification information (including ID card , passport, etc.);
- network identification information (including system account, IP address, email address, and password, passphrase, and passphrase protection answers related to the foregoing)
- personal property information (transaction and consumption records, balance, Paudi Model Beans, coupons, , game exchange code and other virtual property information);
- address book;
- personal Internet access records (including website browsing records, software usage records, click records);
- information on common equipment (including hardware model, device MAC address, operating system, unique device identification code of software list (such as information indicating common equipment with IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information, etc. included);
- location information (including itinerary, precise positioning, accommodation, latitude and longitude, etc.); and
- information about you collected from unique cookies sent to your computer or mobile device, or network beacons on the Paudi Model website, as explained further in Section C below.
We may obtain your account information (head portrait, nickname) from a third party at your direction and bind any account you have with that third party account with your Paudi Model account after you have been sent the Policy so that you can directly log in and enjoy our products and/or services through that third party account. Subject to the relevant laws and regulations, we will use your personal information with a third party after confirming the legality of the source of the personal information. Please be noted that this policy does not apply to these third party. The private policies of those other parties may differ from ours, and Paudi Model does not control over the information that you submit to those third parties.
This policy uses the term ‘Personally sensitive information’. That term refers to personal information that gets additional protection under many privacy laws around the world. Personally sensitive information reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. Personally sensitive information also includes genetic information, biometric information used for the purpose of identifying a natural person and information concerning health or a person’s sex life or sexual orientation. Personally sensitive information may have the potential to endanger personal and property security and could result in damages to personal reputation, physical and mental health or discriminatory treatment, if it is revealed, illegally provided, or abused.
The personally sensitive information that we collect will generally include:
- identification information (including ID card, passport, );
- network identification information (including account name and nickname, email address, and password, and passphrase protection questions and answers related to the foregoing);
- personal information which is considered personally sensitive information under applicable laws; and
- other information (including address book, personal phone number, mobile phone number, itinerary, web browsing history, accommodation and accurate positioning information).
Where required by applicable laws, we will ask for your consent to collect and process your sensitive personal information separately from this policy.
- Purposes for collecting your personal information
Our products and/or services include a number of core functions, which contain those necessary for online shopping, necessary for improvement of our products and/or services, and those necessary for protecting the security of transactions. These functions may not be made available to you before we collect, store and use the following information related to you. If you do not provide the relevant information, you will not be able to enjoy the products and/or services we provide.
We will only collect and use your personal information for the following purposes:
- Functions necessary for online shopping
You first need to register a Paudi Model account to become a Paudi Model user. When you register, you need to at least provide us with your desired Paudi Model account name and password, your own mobile phone number, and e-mail address (for verification). We will verify your identity by sending a SMS verification code or e-mail. Your account name is your default nickname. You can modify and supplement your nickname, gender, date of birth, interests, and information related to the real-name verification, which belongs to your “account information”. Your additions to the account information will help us recommend products to you on a personalized basis and provide you with better shopping experience. However, if you do not provide this additional information, it will not affect the basic functions for your online shopping.
- Display and search
To enable you to quickly find the products you desire, we collect information on the device via which you use our products and/or services (including device name, model, ID, operating system and application version, language settings, resolution, service provider network ID (PLMN)) and the browser you use, so as to display product in the best way. We will also use your personal information above in order to continuously improve and optimize the above functions.
You can also search to find exactly what you need. We will keep your search history for you so as to avoid repeated input or to show products associated with those you have searched for before. ; When your search records are combined with your other personal information, we will treat it as your personal information and process and protect in accordance with the Policy.
When you are ready to buy the products in your shopping cart, Paudi Model will generate an order for you. You need to fill in at least the consignee’s name, delivery address and mobile phone number in the order. At the same time, the order will state the order number, the goods or service you intend to buy, the price you should pay, and the terms of payment. You can additionally fill in the consignee’s fixed-line telephone and email address to ensure that the products can be delivered accurately, but that information does not affect the generation of your order.
Your real-name information may be provided to comply with national laws and regulations [in Paudi Model. The real-name information may include your identity information (such as your identity card , passport), your own photo or video, name, phone number, and so on. These orders may contain information such as your itinerary, hotel address, services you specified, or equipment installation address (possibly your home address).
All of the above information constitutes your “order information”. We will use your order information to conduct your identity verification, determine the transaction, payment and settlement, delivery, retrieve your order for you on our system, and provide customer services and after-sales services for you; we also use your order information to determine if there is an exception in your transaction to protect your transaction.
After your order is placed, you can make payment in a manner provided by PD affiliates or any third party payment institutions (including Paypal payment, UnionPay, etc., collectively, “payment institutions”).The payment function itself does not collect your personal information, but we need to share your Paudi Model order number and transaction amount with these payment institutions so that they can confirm your payment instructions and then make payment. “Affiliate” means any company or agency that currently or in the future controls a party, is under the control thereof, or under the common control with that party as well as the legal representatives of the foregoing companies or agencies. “Control” refers to the ability to influence, directly or indirectly, the management of the companies referred to, whether through ownership, voting shares, contracts, or other forms recognized by the people’s courts.
After you place an order and choose cash on delivery or make payment online, PD’s affiliates or third-party delivery companies that cooperate with Paudi Model (including UPS, DHL etc., hereinafter referred to as “delivery companies”) will deliver for you. You acknowledge that PD’s affiliates or third-party delivery companies in cooperation with Paudi Model will use your order information in the above links to ensure that your ordered products can be safely delivered.
When we deliver products to you, we will assist you in completing real-name certification as required by laws. If we do so, we will use your ID card or other identify verification method to verify your identity. and our couriers must be subject to PD’s confidentiality system.
- Customer services and after-sale services
To activate our telephone customer services and after-sale services, we will use your account information and order information.
To ensure the security of your account, our staff in the call center and online customer services will use your account information to verify your identity with you. When you need us to provide customer service and after-sale services related to your order information, we will check your order information. You will be required to provide information other than the above when communicating with our customer service staff, such as when you request us to change the delivery address, contact person or contact number on your account.
- Functions necessary for improvement of our products and/or services
We may use your order information, browsing history, interests and hobbies (to be selected in the account settings) we collected so as to show you the products or services you are interested in; or suggest what you might want to find while you search. We also obtain other reasonable information on you for the purpose of providing and improving services, including the relevant information that you provided to us when you ask for customer services, replies you give in questionnaire surveys, and the relevant information that we obtain when you interacted with our affiliates and partners. We associate your various devices with each other, so that we can combine information obtained from each of them to provide you with a consistent service across all these devices. We also combine information from your use of one service with that from other services so as to provide you with services, personalized content, and recommendations.
- Functions necessary for protecting the security of transactions
To enhance the security of your system when using our products and/or services, to accurately prevent phishing website fraud and to protect account security, we judge risks about the use of your account via information on your browsing, orders, your frequently used software, and devices and record some links (“URL”) that we believe to be risky; we also collect information about your device to analyze the Paudi Model system, conduct traffic statistics and investigate possible risks, and troubleshoot when you choose to send us abnormal information.
- To enhance your shopping experience on Paudi Model
To make your shopping more convenient or more fun, so as to enhance your online shopping experience in Paudi Model, we collect and use your personal information for the following additional functions If you do not provide this personal information, you may still be able to shop online, but you cannot use these additional functions that can bring you shopping pleasure, or you may need to repeatedly fill in some information when purchasing certain products. These additional functions are:
- Personalized recommendations based on location information
We will collect your location information (we only collect your geographical location at that time, but will not combine the location information to judge your whereabouts) to judge your location and automatically recommend products or services made available in your area.
- Camera-based additional functions
With this function, you can shoot videos, take pictures, scan code.
- Additional functions based on pictures uploaded
You can upload your photos in Paudi Model to shop, share and evaluate products. We will use the photos you uploaded to identify the products you need or use comments that contain the photos you uploaded.
- Additional functions based on voice technology
You can use the microphone directly for voice shopping or to consult and interact with our customer service robots. By using these features, we collect your recordings to identify your needs for shopping, customer service and after-sale services.
- Additional functions basedon address book
We will collect your address book information so that you don’t have to manually input the information in the contacts in your address book when shopping; in order to increase your social fun while shopping, we can also judge whether your friends are also Paudi Model users and get in touch with you in Paudi Model; provided however that we will obtain your consent in advance before we do this.
The above additional functions may require that you allow us to access to your geographic location (location information), camera (camera), photo album (image gallery), microphone, and address book so that we can collect and use the information necessary for these functions. You can check the opening status of your above-mentioned permissions item by item in “Account Settings—Settings—Privacy” in Paudi Model, or “Setting-Privacy” for IOS Users and “Setting-App Permission “ for Android Users, and you can make them available or unavailable at any time (we will guide you in your device system). If you make them [unavailable], we will no longer continue to collect and use the personal information, nor can we provide you with the above-mentioned features corresponding to those authorizations. However, your decision to close will not affect the processing of personal information previously conducted.
- Other purposes
We will also collect and process your personal information in the following circumstances:
- where requested by public authorities in furtherance of their powers or functions, including for national security, public safety, public health and major public interests;
- relating to criminal investigations, prosecutions, trials and execution of judgments;
- for the purposes of protection of material legal rights and benefits such as the lives and properties of the personal information subject or other individuals where it is difficult to obtain the consent of the subject involved;
- the personal information to be collected is made available by the subject of the personal information to the public;
- your personal information is collected from legally disclosed information, such as legitimate news reports, government information disclosure, etc.;
- necessary for signing the contract as required by you;
- necessary for maintaining the safety and stable operation of the products and/or services provided, such as the detection and disposal of the fault at products and/or services;
- required for legal news reports;
- necessary for academic research institutions to conduct statistical or academic research for public interest, to the extent that the personal information contained in the academic research or description results is de-identified;
- other circumstances stipulated by laws and regulations.
Rules for the use of your personal information
- We will use the personal information collected in accordance with the Policy and to provide our products and/or services.
- After collecting your personal information, we will de-identify the data through technical means. One cannot identify the subject with de-identified information. Please understand that in this case we have the right to use information that has been de-identified and to analyze the user database and use it commercially subject to non-disclosure of your personal information.
- When you deregister, we will stop using and delete your personal information.
- We will generate statistics on the use of our products and/or services and share this statistical information with the public or any third parties to demonstrate the overall trends of our products and/or services. However, these statistics do not include any of your identity information.
- When we display your personal information, we will desensitize your information by content substitution and anonymization to protect your information.
When we intend to use your personal information for other purposes not specified in the Policy, or use the information collected for a specific purpose for other purposes, we will notify you by email, pop up notice and any other means available and meeting any other requirements required of us by law.
- How we use Cookie and similar technologies
To satisfy your personalized needs when you are online so that you can get a more relaxed access experience, we will send one or more small data files named cookies on your computer or mobile device. The cookies assigned to you are unique and can only be read by Web servers that publish cookies to your domain. This move is to avoid repeated logins, save your shopping preferences or items in your shopping cart, and so on, so as to provide you with shopping preferences setting, help you optimize the selection and interaction of advertisements, and judge your login status and account or data security.
You can manage or delete cookies at your own discretion. Most web browsers automatically accept cookies, but you can usually modify your browser’s settings to reject cookies if you want. But if you do this, you may need to personally change user settings every time you visit Paudi Model site; the corresponding information you have previously recorded will also be deleted and it may have an impact on the security of the services you use. In some jurisdictions, we are required to ask for your consent before we deposit cookies on your device.
Use of network Beacon and similar technologies
In addition to cookies, we also use other technologies on the website such as Beacon. Our web pages often contain electronic images (called “single-pixel” GIF files or “network beacon”). We use network beacons in the following ways:
- applying network beacon on Paudi Model website to calculate the number of user visits and identify registered Paudi Model users by accessing the cookie.
- providing you with personalized services through the cookie information.
- Legal bases for collecting your personal information for Visitors from European Union
We generally use your personal information for the purposes outlined in Section B because it is:
- necessary for the legitimate interests of PD, including providing products and services of a high standard, keeping our customers satisfied, and meeting our accountability and regulatory requirements around the world, in each case provided such interests are not overridden by your privacy interests;
- necessary for us to enter into, and perform our obligations under, our contract with you, such as when we use your personal information for registration and delivery;
- necessary for compliance with a legal obligation under EU law or the laws of a Member State (e.g. any mandatory disclosures to an authority, regulator or government body); or
- in some cases, we have obtained your prior consent.
- How we share, transfer or make available your personal information
We will share, transfer or make available your personal information as follows:
- We share your personal information with our affiliates. However, we only share it on a need-to-know basis and will be bound by the purposes stated in the Policy. If our affiliates are to change the intended purposes for which they use your information, they will notify you in advance and seek your consent if necessary.
- We share your order, account, device and location information with partners and other third parties to ensure the smooth completion of our services. However, we will only share necessary personal information for the purposes set out in Section B. Our partners have no right to use the shared personal information for any other purposes. Our partners include:
- Suppliers of goods or technical services
We share your personal information with third parties supporting our functions. These third parties provide the following types of support to us: infrastructure technical services, logistics and distribution services, payment services, professional advisory services, and data processing for us. The information is disclosed to make available the core functions of our products and/or services. For example, we must share your order information with a logistics service provider to arrange delivery; or we need to notify a third party payment institution of your order number and transaction amount so that it can confirm your payment instructions and then make payment.
- Third-party merchants
It is a must to share your order information and necessary information about the transaction with a third-party merchant to effect your purchase of goods or services, and to enable it to complete the follow-up after-sale services.
- Partners who commission us to promote
Sometimes, we market other companies to users of our products and/or services. We share your indirect user image formed based on your personal information in combination with non-personal information with the partner whocommissioned us to promote (the “client”). However, we will only provide information on the coverage and effectiveness of the promotion to the client rather than your personal identity, or we will aggregate this information so that it does not identify you. For example, we can tell the client how many people saw its promotional information or purchased its products with the marketing information, or provided them with statistical information that could not identify personal identity to help them understand its audience or customers.
- We will transfer your personal information to companies, organizations or individuals, for mergers, acquisitions, asset transfer, or similar transactions; if personal information is involved in the transfer. We will require companies and organizations to hold your personal information to be bound by the Policy. Otherwise, we will require them to ask for your permission again.
- In order to comply with laws, enforce or apply our conditions of use and other agreements, or to protect the rights and property or safety of PD, you or other Paudi Model customers, such as preventing fraud and other illegal activities and reducing credit risks, we will exchange information with other companies and organizations. However, this does not include selling, renting, sharing or otherwise disclosing personal information for profit making purposes in violation of the commitments made in the Policy.
- Public disclosure
We will make available your personal information to the public only under the following conditions to the extent that security measures generally accepted in the industry have been taken:
- At your request, and limited to the personal information you designate in the manner you have requested;
- As required by laws and regulations, mandatory administrative enforcement or judicial orders, we may publicly disclose your personal information of the required type in a manner requested. Subject to laws and regulations, when we are requested to disclose, we will require the corresponding legal documents, such as summons or investigation letters. We firmly believe that the information required to be provided by us shall be as transparent as possible to the extent permitted by laws. All requests have been carefully reviewed to ensure that they are legal and we will only disclose the data that the law enforcement agencies have legal right to obtain for specific purposes. As permitted by laws and regulations, we will disclose documents under the protection of encryption keys.
For companies, organizations and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requesting them to process personal information by taking relevant confidentiality and security measures in accordance with our instructions and this Policy. In order to ensure data security and control by third parties, we have launched Cloud Ding services to provide secure and reliable data usage and storage environments in the cloud to ensure the security of user data. In the use of personal sensitive data, we require third parties to adopt data desensitization and encryption technologies to better protect user data.
Please note that some of the recipients of your personal information referenced above will be based in countries outside of your country of residence whose laws may not provide the same level of data protection as your country. If you reside in the European Union, we may transfer your data to countries/territories including Mainland China, Hong Kong, China
In such cases, we will ensure that there are adequate safeguards in place to protect your personal information that comply with our legal obligations. If you are resident in European Union, to ensure this level of protection for your personal information, we typically use a data transfer agreement with the recipient based on standard contractual clauses Further details of the transfers of your personal information outside of your country of residence and the adequate safeguards used by us in respect of such transfers (including copies of relevant agreements) are also available from us by contacting firstname.lastname@example.org.
- How weprotect your personal information
We value personal information security and will take all reasonable and practical measures to protect your personal information. That said, the Internet is not absolutely secure. Communication methods with other users, such as e-mail, instant messaging, and social software, cannot be fully encrypted. We recommend that you use complex passwords when using such tools, and take care to protect your personal information.
We set out below the security measures taken to protect your personal information:
- Data security technical measures
We will take appropriate technical and organizational measures security protection measures, including reasonable systems and security technologies, to prevent unauthorized access, modification and loss of your personal information.
Paudi Model’s network services are based on encryption techniques such as transport layer security protocols. Paudi Model provides browsing services through https and other methods to ensure the security of user data during transmission.
Paudi Model applies encryption techniques to save on an encrypted basis user’s personal information and isolate it through isolation techniques.
In the use of personal information, such as display and correlation calculations, we will use a variety of data desensitization techniques including content substitution and SHA256 to enhance the security of personal information in use.
Paudi Model adopts strict data access control and multiple identity authentication technologies to protect personal information and prevent data from being used illegally.
Paudi Model adopts code security automatic inspection and data access log analysis technology to conduct personal information security audits.
- Other security measures taken by Paudi Model to protect personal information
Paudi Model manages and regulates the storage and use of personal information by establishing a data classification system, data security management specifications, and development specifications.
Paudi Model controls data security in an all-round way through signing confidentiality agreements with those who will access to the information, monitoring and auditing mechanisms.
Paudi Model has a data security committee consisting of a full-time information protection department and data security emergency response organization to promote and protect personal information security.
Safety certification and service: Our infrastructure cloud technology designed to store your personal data has been certified by the Data Center Alliance as a “Trusted Cloud” certification at [the three level, ]the three-level certification of the Ministry of Public Security for security level protection.] Also, ISO27000 certification has been obtained.
Strengthen safety awareness: We also hold safety and privacy protection training courses to strengthen employees’ awareness of the importance of protecting personal information.
- We only allow employees of PD and PD affiliates and partners to access personal information on a need-to-know basis and set strict access control and monitoring mechanisms for this purpose. We also bind all persons who may come into contact with your personal information with confidentiality obligations. Those who fail to fulfill the obligations may be subject to legal liabilities or have their relationship with PD terminated.
- We will take all reasonable and practical measures to avoid collecting uncorrelated personal information.
- Security incident disposal
When trading goods or services with a third party through the Paudi Model website, you will inevitably disclose your personal information, such as contact details or postal address, to the counterparty or potential counterparties. Please properly protect your personal information and provide it to others only when necessary.
In order to deal with possible risks of leakage, damage, and loss of personal information, PD has established a number of systems to clarify the classification and grading standards for security incidents and security vulnerabilities and the corresponding processing procedures. PD has also established a special emergency response team for security incidents. It will, according to the requirements for the handling of security incidents, implement security plans for different security incidents, stop loss, conduct analysis, positioning and formulate remedial measures; moreover, it will trace to the source and crackdown in concert with the authorities .
In the event of a personal information security incident, we will inform you without undue delay (in accordance with applicable laws and regulations) of the basic information and possible impact of the security incident, measures we have taken or will take, suggestions on the precautions you can take to reduce risks, remedial measures for you, etc. We will also inform you on a timely basis by e-mail, letter, telephone, notice, etc., again in accordance with applicable laws and regulations When it is difficult to notify a personal information subject on an individual basis, we will issue an announcement in a reasonable and effective manner is made instead.
If you have any questions about personal information protection, you can contact us through the contact information at the bottom of the Policy. If you find that your personal information has been made known, especially your account and password, please contact us immediately through the contact information set out in [How to contact us] at the bottom of the Policy so that we can take appropriate measures.
- Personal information preservationand retention
Your personal information will be fully stored within the territory of the People’s Republic of China. If you apply for cross-border services and therefore, your personal information will be transferred overseas to effect the transaction, we will seek your consent separately and request the receiving party to process the personal information by taking relevant confidentiality and security measures in accordance with our instructions and the Policy.
We will hold your personal information for as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. Unless otherwise specified by laws and regulations, we will remove or anonymize your personal information within one month from the date when your account is cancelled. If the foregoing period expires, we will remove or anonymize your personal information.
Please note that when you successfully deregister your Paudi Model account, we will give you a one-month cooling-off period as of the deregistration date, during which, you can at any time apply for resumption of your cancelled Paudi Model account. To resume the functions under your Paudi Model account, we will not remove or anonymize your personal information during the cooling-off period. If you do not resume your Paudi Model account or explicitly refuse to resume your Paudi Model account during the cooling-off period, we will remove or anonymize your personal information.
If we terminate services or operation, we will notify you at least 30 days in advance and remove or anonymize your personal information after the termination of services or operation.
- How to manage your personal informationand your rights
PD attaches great importance to your concern for personal information and makes every effort to protect your right to access, correct, delete, and withdraw consent to use, your personal information, so that you have full capacity to protect your privacy and security. These rights are set out below. Where you exercise your rights, we will honor your request as required under applicable laws, but your rights are not absolute as they do not always apply and exemptions may be applicable.
- The right to access and correct your personal information
Unless provided by laws and regulations, you have the right to access to and correct your personal information at any time, including:
- Account information: On the PC side, you can check all your personal information submitted to Paudi Model in “Personal Information” menu on “My Paudi Model” page. You can also update personal information other than real-name authentication information (refers to the name and ID information used for real-name authentication) through the above-mentioned methods. For the mobile App: if you intend to change account name or personal information: Home – click “My Account” – click “Settings” at the upper right corner for IOS users or click head portrait for account settings – personal information;: Home – click “My Account” for “My Paudi Model” – click “Settings” at the upper right corner for IOS users or click head portrait for account settings – account security; interests and hobbies: Home – click “My Account-Shopping Preferences” for My Paudi Model – Commodities, Stores and Contents Followed and My Activities.
- Delivery information: On the PC side, you can add, change, and delete your delivery address (including the consignee’s name, delivery address, and consignee’s phone number or e-mail) at any time by visiting the “Shipping Address” on My Paudi Model” page. For mobile App, go to the Home – click “My Account” for “my Paudi Model” – click “Settings” at the upper right corner for IOS users or click head portrait for account settings – Shipping address. You can also set the most commonly used delivery address as the default one, so that when you do not change the delivery address when you purchase next time, your products will be delivered to your default address.
- Order information: On the PC side, you can view all completed and pending orders or orders subject to after-sale services by visiting “My Orders” page. For the mobile App: Home – click “My Account” for my Paudi Model – My orders/receivables/on the transit/returned or replaced. You can choose to delete the completed orders to delete your order information, but this may make it impossible for us to accurately determine your purchase information and therefore it is difficult to provide the corresponding after-sale services.
- Browsing information: You can access to or clear your search history, view and modify interests, and manage other data. For the mobile App: search history: Home – click “My Account” for my Paudi Model – browsing records; interests and other data: Home – click “My Account” for my Paudi Model -products, stores and contents followed and my activities.
- Comments: You can access to or update or clear your personal comments on the PC side. On mobile App: My Paudi Model – Write a Review..
- Shopping Preference: You can personally add personal information such as your wish list, favorite stores, etc. in “My Account e” under mobile App. This will make it easier for you to purchase related products and services, and for us to recommend products in which you may be interested. You can delete and modify your above information in this way.
Please feel free to contact us if you need to access or correct other personal information arising from your use of our products and/or services. We will respond to you in a manner and by the deadline set out in the Policy.
- The right to request that your personal information be transferred
Subject to the limitations of applicable laws, where processing your personal information is necessary for entering into or performing our obligations under a contract with you or is processed as a result of your consent, you may have the right to request your personal information be transferred to you or another controller (where technically feasible).
- The right to deletion of your personal information
Subject to the limitations of applicable laws, you may request for us to delete your personal information. If we decide to respond to your request for removal, we will also notify any entity that obtains your personal information from us, requesting for removal in a timely manner, unless otherwise required by laws and regulations, or the entities are authorized by you.
- The right to object to the processing of your personal information
Subject to the limitations of applicable laws, you may request to object to the processing of your personal information by changing the scope within which we can continue processing that personal information.
- The right to change your authorization scope or withdraw your authorization
To the extent you have given us authorization to collect and process your personal information, you may withdraw that authorization to process your personal information for certain purposes by deleting information, turning off device functions, changing privacy settings on Paudi Model website or in the software. You can also withdraw your authorization granted to us by deregistration so that we cannot continue collecting your personal information.
Please understand that each business function requires some basic personal information. Once you withdraw your consent or authorization, we cannot continue providing you with the services for which you withdraw consent or authorization, and will not process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the processing of personal information previously conducted according to your authorization.
You can apply to us for deregistration directly via email@example.com. After you deregister, we will stop providing products and/or services to you and delete your personal information as required by you unless otherwise stipulated by laws and regulations.
- If you do not want to receive any promotional information we send to you, you can cancel it at any time by taking the following steps:
(1) You can cancel promotion information subscribed via email with the unsubscribe link attached. .
(2) We will work with third-party platforms or media (“platforms”) to recommend personalized products to you based on your personal information. The personal information includes your shopping history on the site, access to the sites of PD’s affiliates, and interests and hobbies you have entered in your account settings. The platforms only allow us to display products. The links thereto are personalized products in Paudi Model and managed by Paudi Model. Therefore, we do not provide advertisers with any of your personal information. We allow you to block in the recommendation window so you can block ads that you don’t like. If you are not willing to accept Paudi Model’s recommendation services on a single platform, please contact the platform to close it. You know and understand that the platform is an entity that is engaged in business independently and not under the management of Paudi Model.
(3) In order to protect your privacy, we will not send you any marketing information related to sensitive content such as religious beliefs, sex, illness and others to you in any manner or means.
Responding to your requests
Subject to the applicable law, you are entitled to submit the above requests by contacting us through firstname.lastname@example.org, We do not charge you for your reasonable request in principle; however, we will charge a certain amount of cost for repeated requests that exceed a reasonable limit. We may reject those requests that are duplicative, require excessive technical means (for example, developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or that we are permitted to reject under applicable laws.
In certain situations, we may not be able to respond to your request. These situations may include situations:
- relating to national security and national defense security;
- relating to public safety, public health, and major public interests;
- relating to criminal investigation, prosecution and trial;
- where there is sufficient evidence that you have subjective intentions or abuse rights
- where a response will result in serious damages to the legitimate rights and interests of you or other individuals and organizations.
Complaints to a data protection authority
You have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your data has arisen.
- Protection of minors’ information
PD attaches great importance to the protection of minors’ personal information. If you are a minor under the age of 18, you must obtain prior written consent from your parent or legal guardian before using our products and/or services. PD protects personal information of minors in accordance with applicable laws and regulations.
For the personal information of minors collected with the consent of parents or legal guardians, we will only use or publicly disclose it when permitted by laws, explicitly consented by the parent or guardian or required for protecting the child.
If we find ourselves collecting personal information of a minor without the prior consent of a verifiable parent or legal guardian, we will try to delete it as soon as possible.
- Notices and amendments
For significant changes, we will also announce in a noticeable manner, explaining specific changes to the Policy in a manner including but not limited to emails, text messages, or special tips on the browsing page.
For the purpose of the Policy, significant changes include but are not limited to:
- significant changes in our service model, for example, the purpose of processing personal information, the types of personal information handled, the manner to use personal information, etc.;
- major changes in ownership structure, organizational structure, and so on, such as changes in owner as a result of business adjustment, bankruptcy, mergers and other similar transactions;
- changes in the main objects of personal information sharing, transfer or public disclosure;
- major changes in your rights to participate in the processing of personal information and the way to exercise them;
- any changes in the departments in charge of handling personal information security, contact information, and reporting channels;
- there is a high risk indicated in the personal information security impact assessment report.
We will also archive the old version of this Policy for your review.
- How to contact us
If you have any questions, opinions or suggestions about the Policy or related issues, you can at any time email us at email@example.com or contact us otherwise.
We have set up a full-time information protection department (or personal information protection specialist). You can contact by emailing firstname.lastname@example.org.
Notes: The Policy was updated on July 14, 2018 and will take effect as of July 25, 2018.