Terms

Your trust is of great importance to us, and we are fully aware of the significance of your personal information to you. In light of this, the find.ly Service Provider (or "we") have formulated this Privacy Policy (hereinafter referred to as "this Policy / this Privacy Policy").

This Policy applies to the find.ly service you use and the various business functions included in that service (collectively, "our products and/or services"). Before using our products and/or services, please read this Policy carefully and thoroughly understand its contents, especially the terms highlighted in bold/underlined. You should read them carefully and use the products or services only after confirming that you fully understand and agree to them. By using our products and/or services, you acknowledge that you have fully understood and agreed to this Policy.

To provide you with a better experience of our products and services, we are continuously improving our technology and may introduce new or optimized features from time to time. This may require the collection and use of new personal information or changes to the purpose or manner of using personal information. In such cases, we will separately explain the purpose, scope, and usage of the relevant information to you by updating this Policy, displaying pop-ups, page prompts, etc., and provide you with the means to choose whether to consent. We will collect and use the information only after obtaining your explicit consent. If you have any questions, comments, or suggestions about the content of this Policy, you can contact us through find.ly's online customer service.

Part I Privacy Policy

This Privacy Policy section will help you understand the following:

• How we collect and use your personal information
• How we use cookies and similar technologies
• How we share, transfer, and publicly disclose your personal information
• How we protect your personal information
• How we store your personal information
• How you can manage your personal information
• How we handle the personal information of minors
• How this Privacy Policy is updated
• How to contact us

How we collect and use your personal information

When you use our products and/or services, we collect and use your personal information based on the following scenarios:

(1) To realize the functions necessary for promotion

(2) User registration

To register as a user and use our services, you need to provide your mobile phone number, the intended account name, and password. We will send you a verification code to verify your identity. After registration, you can further improve your personal information such as your real name, ID card number, mobile phone number, and contact email in your find.ly account.

(3) Data collection and use for Facebook-related functions
When you choose to use functions such as "Facebook Login" or "Link Facebook Account", we will collect the following information from your Facebook account based on the permissions you grant: Facebook nickname, profile picture, email address (if you allow apps to obtain it through Facebook settings), and Facebook ID.
The purposes of collecting this information include:

• Simplifying the login process: Log in directly with your Facebook account without the need for repeated registration.
• Personalizing services: Optimizing the content displayed on the platform (such as matching interest tags) based on your public Facebook information.
• Supporting cross-platform functions: If you use Facebook-related business functions (such as linking a Facebook page), we will use the above information to realize services such as content synchronization and data analysis.
  
• (4) Real-name authentication
  
• To ensure that we are providing services to you personally, we may verify your identity based on the information in your find.ly account. You can provide us with appropriate identification documents (ID card, passport, household register, and other identification information) to complete the verification process.
  
• (5) Showing you information about our products/services
  
• In the course of your use of our services, to identify abnormal account status, understand product suitability, and provide you with more relevant page displays and search results, we may automatically collect and store web log information about your usage, including:
  
• Device information: Based on your specific actions during access and/or use, we receive and record information about the device you are using, including device model, operating system version, unique device identifiers (IMEI/Mac/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information) and other hardware and software characteristics, as well as information related to the device's location (including your authorized GPS location and sensor information such as WLAN access points, Bluetooth, and base stations).
  
• Service log information: When you use the products or services provided by our website or client, we automatically collect details of your use of our services and store them as relevant web logs. For example, the content of your search queries, IP address, browser type, telecom operator, language used, access date and time, and records of the web pages you visit.
  
• Please note that information such as device information and device operation information that cannot individually identify a specific natural person is non-personal information. If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, such non-personal information will be regarded as personal information during the period of combined use. Unless we obtain your authorization or as otherwise specified by laws and regulations, we will anonymize and de-identify it.
  
• If you have any questions or objections to the personalized product or service information (if any) you receive, you can contact us through the contact information listed at the beginning of this Agreement.
  
• (6) Helping you complete order placement and order management
  
• When you order specific goods and/or services in our products and/or services, we will generate an order for you to purchase those goods and/or services through our system. In the process of placing an order, you are required to provide at least the consignee's name, delivery address, and the consignee's contact phone number. The order will contain information about the goods and/or services you have purchased, the specific order number, the time the order was created, the amount you should pay, etc. We collect this information to help you complete the transaction smoothly, protect your transaction security, check order information, provide customer service and after-sales service, and for other purposes we have explicitly informed you of.
  
• You can order goods and/or services for another person through the find.ly Platform, and you will be required to provide the aforementioned personal information of the actual orderer.
  
• To help you understand and manage order information, we will collect the order information generated by you in the process of using our services to display to you and facilitate your management of orders.
  
• (7) Helping you keep track of the delivery status of goods or services
  
• To keep you informed of and confirm the progress and status of deliveries, and to provide you with after-sales and dispute resolution services, you agree that we may collect delivery progress information from logistics-related service providers.
  
• (8) Helping you withdraw your balance
  
• When the balance in your account reaches the withdrawable amount, you can withdraw your balance by providing your name, ID card number, bank card number, issuing bank, and the region where the bank card is located.
  
• (9) Functions necessary to ensure transaction security
  
• To improve the security of our systems when you use our products and/or services, to more accurately prevent phishing scams, and to protect account security, we may determine the risk of your account by understanding your browsing information, order information, device information (including MAC address), and may record links that we consider risky ("URLs"); if you choose to send us abnormal messages, we may also collect your device information to analyze find.ly system problems, count traffic, identify possible risks, and check abnormal messages.
  
• (10) Other additional services provided to you
  
• To provide you with more convenient and better services and strive to enhance your experience, we may collect and use your personal information in the following additional services we provide to you. If you do not provide this information, it will not affect your use of basic services, but you may not be able to enjoy the user experience brought by these additional services. You can check the status of these permissions item by item in your device settings and decide whether to turn them on or off at any time.
  
• Please note that by turning on any permission, you authorize us to collect and use the relevant personal information to provide the corresponding service. By turning off any permission, you revoke your authorization, and we will no longer collect and use the relevant personal information based on that permission, nor will we be able to provide you with the service corresponding to that permission. However, your decision to turn off the permission will not affect the collection and use of information based on your previous authorization.
  
• (11) Other rules for the collection and use of personal information
  
• 11.1 If the information you provide contains personal information of other users, you need to ensure that you have obtained legal authorization before providing us with such personal information.
  
• 11.2 If we use your personal information for purposes not stated in this Policy, or use information collected for a specific purpose for other purposes, or actively obtain your personal information from a third party, we will obtain your prior consent.
  
• Supplementary notes on Facebook data:
  
• We will only access your Facebook information after you have given explicit authorization, and will not collect content beyond what is necessary for the function (such as your Facebook friend list, unless you authorize it separately).
• If you do not use Facebook-related functions, we will not actively obtain any Facebook data.
  
• 11.3 Exceptions for obtaining authorized consent
  
• You fully understand and agree that we may collect and use your personal information without your authorized consent in the following circumstances, and may not be able to respond to your requests for correction/rectification, deletion, cancellation, withdrawal of consent, or information inquiry:
  
• Related to national security and national defense security.
• Related to public safety, public health, and major public interests.
• Related to criminal investigation, prosecution, trial, and enforcement of judgments and other judicial or administrative law enforcement.
• For the purpose of safeguarding your or other individuals' life, property, and other major legitimate rights and interests, but it is difficult to obtain your consent.
• Personal information that you have voluntarily disclosed to the public.
• Personal information collected from legally publicly disclosed information, such as legitimate news reports, government information disclosure, and other channels.
• Necessary for the conclusion and performance of relevant agreements or other written documents with you.
• Necessary for maintaining the safe and stable operation of the products and/or services provided, such as detecting and handling product and/or service failures.
• Necessary for legitimate journalism.
• When an academic research institution conducts statistical or academic research necessary for the public interest and provides the results of academic research or descriptions to the public, the personal information contained in the results is de-identified.
• Other circumstances specified by laws and regulations.
  
• Please be aware that, in accordance with applicable laws, if we take technical and other necessary measures to process personal information in such a way that the data recipient cannot re-identify a specific individual and cannot recover it, or if we de-identify the collected information for research, statistical analysis, and forecasting purposes, to improve the content and layout of the find.ly Platform, to support products or services for business decisions, and to improve our products and services, such processed data may be used without separate notice to you and without your consent.

How we use cookies and similar technologies

(1) Cookies

To ensure the efficient and effective operation of the website and make your visit easier, we may store information on your computer or mobile device: these may be cookies, Flash cookies, or other local storage provided by your browser or associated applications (collectively, "cookies").

Please understand that some of our services can only be provided through the use of cookies. If your browser or browser add-on service allows, you can modify your acceptance of cookies or refuse our cookies, but refusing our cookies may in some cases affect your ability to access the website securely and use the services we provide.

If your browser or browser add-on service allows, you can modify your acceptance of cookies or refuse our cookies, but doing so may in some cases affect your ability to access our website securely and may require you to change your user settings each time you visit our website.

(2) Web beacons and pixel tags

In addition to cookies, we use other similar technologies on our website, such as web beacons and pixel tags. For example, an email we send you may contain a link to an address that links to content on our site. If you click on that link, we will track that click to help us understand your preferences for products or services, so that we can proactively improve our customer service experience. A web beacon is typically a transparent image embedded in a website or email. With the help of pixel tags in emails, we can tell if an email has been opened. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.

How we share, transfer, and publicly disclose your personal information

(1) Sharing

We will not share your personal information with any company, organization, or individual outside of Chengdu Pairuo Import & Export Trading Co., Ltd., except in the following cases:

Sharing rules with Facebook:

• To realize functions such as Facebook Login and content sharing, we will share necessary technical data (such as your login status, metadata of shared content) with Facebook, but will not share sensitive content such as your find.ly account password and payment information.
• The use of shared data is subject to Facebook's Developer Policy and this Policy. For details, please refer to Facebook's official privacy policy.
  
• 1.1 Sharing with explicit consent: We will share your personal information with other parties after obtaining your explicit consent.
  
• 1.2 Sharing under legal circumstances: We may share your personal information with the public in accordance with the provisions of laws and regulations, the need for litigation dispute resolution, or as requested by administrative or judicial authorities in accordance with the law.
  
• 1.3 Sharing at your active choice: When you purchase goods or services through the find.ly platform, we will share the necessary transaction-related information in your order information with the provider of the relevant goods or services according to your choice, to meet your transaction and after-sales service needs.
  
• 1.4 Sharing with affiliates: To facilitate our joint provision of services to you based on affiliated accounts, to identify abnormalities in member accounts, or to protect the personal and property safety of find.ly affiliates, other users, or the public from infringement, your personal information may be shared with our affiliates. We will only share necessary personal information, which is subject to the purposes stated in this Privacy Policy. If we share your sensitive personal information or if our affiliates change the purpose of using and processing personal information, we will seek your authorized consent again.
  
• 1.5 Sharing with authorized partners: Only for the purposes stated in this Privacy Policy, some of our services will be provided jointly by us and our authorized partners. To provide better customer service and user experience, we may share some of your personal information with our partners. We will only share your user information for legal, legitimate, necessary, specific, and explicit purposes, and only share as much user information as is necessary to provide the services. Our partners have no right to use the shared user information for any other purpose.
  
• Currently, our authorized partners include the following types: suppliers, service providers, and other partners. We send information to suppliers, service providers, and other partners who support our business by providing basic technical services, customer service, consulting, analysis, and other professional services.
  
• For companies, organizations, and individuals with whom we share user information, we enter into strict data privacy agreements requiring them to handle personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.
  
• (2) Transfer
  
• We will not transfer your personal information to any company, organization, or individual, except in the following cases:
  
• 2.1 Obtain your prior express consent or authorization.
  
• 2.2 As required by applicable laws and regulations, legal proceedings, and mandatory administrative or judicial requirements.
  
• 2.3 As provided for in relevant agreements signed with you (including online signed electronic agreements and corresponding platform rules) or other legally agreed documents.
  
• 2.4 In the event of a merger, acquisition, asset transfer, or similar transaction involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy; otherwise, we will require the company or organization to seek your authorized consent again.
  
• (3) Public disclosure
  
• We will only publicly disclose your personal information if we take industry-standard security measures and in the following cases:
  
• 3.1 Disclose the personal information you specify in the manner you expressly agree to meet your needs.
  
• 3.2 If laws, regulations, mandatory administrative enforcement, or judicial requirements require us to provide your personal information, we may publicly disclose your personal information based on the type of personal information requested and the manner of disclosure. To the extent permitted by laws and regulations, when we receive such a disclosure request, we will require a legal document such as a subpoena or inquiry letter. We strongly believe in being as transparent as possible about the information we are asked to provide, to the extent permitted by law. We carefully review all requests to ensure they have a legitimate basis and are limited to data that law enforcement has a legitimate right to obtain for specific investigative purposes. To the extent permitted by laws and regulations, the documents we disclose are protected by encryption keys.
  
• (4) Exceptions for sharing, transferring, and publicly disclosing personal information without prior authorized consent
  
• In the following circumstances, the sharing, transfer, or public disclosure of your personal information does not require prior authorized consent from you:
  
• 4.1 Related to our fulfillment of obligations under laws and regulations.
  
• 4.2 Related to national security and national defense security.
  
• 4.3 Related to public safety, public health, and major public interests.
  
• 4.4 Related to criminal investigation, prosecution, trial, and execution of judgments.
  
• 4.5 For the protection of your or other individuals' life, property, and other major legitimate rights and interests, but it is difficult to obtain your consent.
  
• 4.6 Personal information that you have disclosed to the public on your own.
  
• 4.7 Personal information collected from legally publicly disclosed information, such as legitimate news reports, government information disclosure, and other channels.
  
• According to the law, sharing or transferring de-identified personal information and ensuring that the data recipient cannot recover and re-identify the subject of the personal information is not an act of sharing, transferring, or publicly disclosing personal information to the public, and the storage and processing of such data will not require separate notification to you or your consent.

How we protect the security of your personal information

(1) We take the security of your information very seriously. We have implemented reasonable and practicable security measures in accordance with industry standards to protect your information from unauthorized access, public disclosure, use, modification, damage, or loss. For example, data exchange between your browser and our servers is protected by SSL protocol encryption; we also provide secure browsing through the HTTPS protocol on the find.ly Platform; we use encryption technology to enhance the security of personal information; we use trusted protection mechanisms to prevent malicious attacks on personal information; we deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

(2) We have an industry-leading data security management system that focuses on data

Last updated: July 23, 20