IMPROVED Privacy Policy
Special Notice:
This policy applies solely to the products and services provided by Hainan IMPROVED Information Technology Co., Ltd. and its affiliated companies (hereinafter referred to as "we" or "IMPROVED"), as well as the extended functions of these products and services (collectively referred to as "IMPROVED Services"). This includes IMPROVED’s apps, websites, clients, mini programs, and other new forms of products and services that may emerge with technological advancements. However, this policy does not apply to services provided to you by third parties on the IMPROVED website.
If a specific product we provide has its own separate privacy policy or special provisions within its corresponding user agreement, that product's privacy policy shall take precedence. For any matters not covered in that product's privacy policy or user agreement, the provisions of this Privacy Policy shall apply.
Please carefully read the IMPROVED Privacy Policy (especially the bold and underlined sections) and ensure that you understand our rules regarding the handling of your personal information. If you have any questions during the reading process, you may contact us using the contact information provided below.
Last updated: Year 202_ Month _ Day _
Effective Date: Year 202_ Month _ Day _
Contact Phone: 4008210742
Contact Email: privacy@ifengpai.com
Contact address:
Room C107, 2nd Floor, Area E, Fuxing City, No. 32 Binhai Avenue, Longhua District, Haikou City, Hainan Province, China
Introduction
IMPROVED places great importance on users’ privacy and the protection of personal information. We will take corresponding security measures in accordance with laws and regulations to strive to ensure that your personal information remains safe and under control. When you use our products/services, we may collect and use your relevant information.
Through this IMPROVED Privacy Policy (“this Privacy Policy”), we aim to explain how we collect, use, store, share, and transfer such information when you use our products/services, as well as how we provide you with access to, updating, deleting, and protecting this information.
- I. How We Collect and Use Your Personal Information
Personal information refers to various types of information recorded electronically or by other means that can identify a specific natural person either alone or in combination with other information, or reflect the activities of a specific natural person. Personal sensitive information refers to personal information that, once disclosed, illegally provided, or misused, may endanger personal and property safety, easily cause damage to personal reputation, physical and mental health, or lead to discriminatory treatment. The personal information involved in this Privacy Policy includes: basic information (including personal name, date of birth, gender, address, personal phone number, email address); personal identification information (including ID card, passport, Mainland Travel Permit for Hong Kong and Macau residents, Five-year Mainland Travel Permit for Taiwan residents); personal biometric information (including voiceprint, facial recognition features); network identity identification information (including personal account, IP address, personal digital certificate); personal property information (including transaction and consumption records, balance, coupon virtual asset information); contacts; personal internet usage records (including webpage browsing history, software usage records, click records); information of frequently used personal devices, including hardware model, device MAC address, operating system type, software list, unique device identification codes (such as IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information describing basic conditions of personal frequently used devices); personal location information (including precise location information, latitude and longitude). [The parts in bold and underlined above belong to personal sensitive information.]
We will only collect and use your personal information for the following purposes:
- (1) Situations where you must authorize us to collect and use your personal information
Our products/services include some core functions, including: functions necessary to realize online second-hand electronic product transactions, functions necessary to improve our services, and functions necessary to ensure transaction security. We may collect and use the following information related to you in order to achieve the above functions. If you do not provide the relevant information, you will not be able to enjoy the products/services we provide. These functions include:
- 1. Registration and login
- (1) Registration: You need to first register an IMPROVED account to become an IMPROVED user. When you register an IMPROVED account, you are required to provide us with your personal mobile phone number at minimum. We will verify the validity of your identity by sending an SMS verification code. Please note that if the mobile phone number you provide has not been registered on this platform before, we will directly register an IMPROVED account for you via quick registration and log you in.
- (2) Login: When you use the login function, you need to provide us with the mobile phone number you used during registration and enter the verification code to log in. When you log in using your mobile phone number, the phone number is essential for the login function; if you do not provide it, you will not be able to log in normally.
- 2. Functions necessary to facilitate online second-hand electronic product transactions
- (1) Testing function
Function Testing Service: IMPROVED requires you to enable camera permission to use this function to inspect the relevant functions of the second-hand electronic product you intend to trade via online video. This includes, but is not limited to, testing features such as "buttons," "camera," "Face ID/Touch ID," as well as appearance aspects including but not limited to the "screen," "frame," and "back cover," in order to accurately assess the recycling price. Please be aware that even if you have agreed to enable camera permission, we will only obtain information when you actively use the camera, such as taking photos or recording videos.
The above functions may require you to grant us access to your device’s camera to collect and use information involved in these functions. Please note that by enabling these permissions, you authorize us to collect and use this personal information to perform the aforementioned functions. If you disable these permissions, you revoke this authorization, and we will no longer collect or use such personal information. Consequently, we will be unable to provide the function testing for the items related to these permissions, and you will not be able to proceed with the next steps of pricing and transaction.
We understand that some users may receive calls from the police after ending a FaceTime call, inquiring whether they have encountered fraud. This is usually part of the police’s proactive measures to prevent fraud and protect public safety. Please rest assured that during FaceTime calls, we only perform mobile device checks and do not access your bank accounts, passwords, or other sensitive information. However, you should remain vigilant when using any communication tools. Special reminder: If during a FaceTime call, the other party asks you to provide sensitive information such as your bank card number, password, or verification codes, please refuse and hang up immediately. Finally, if you do not frequently use FaceTime, you may choose to disable this feature to reduce unnecessary risks. You also agree that we may send you reminders of the above information via SMS, and you can opt out of receiving such messages after you receive them.
- (2) Order placement function
When you are ready to sell your second-hand electronic product, IMPROVED will obtain your order. When applying for a recycling transaction, you need to truthfully upload your personal identification information (and complete further real-name authentication with facial recognition if necessary to verify your identity). You must fill in at least your name, identification number, shipping address, and phone number in the order. Additionally, the order may include the order number, device information of the second-hand electronic product you intend to sell, total recycling price, and payment method.
All the above information constitutes your "order information." We will use your order information to verify your identity, confirm transactions, process payments and settlements, complete the recycling process, query your orders, and provide customer service and follow-up support; we will also use your order information to detect any abnormalities in your transactions to protect your transaction security.
After you confirm the IMPROVED recycling, you can choose to receive the recycling payment through the payment services provided by IMPROVED’s affiliates or third-party payment institutions cooperating with IMPROVED (including WeChat Pay, Alipay, UnionPay, and other payment channels, hereinafter referred to as “Payment Institutions”). The payment function itself does not collect your personal information, but we need to share your IMPROVED order number and transaction amount information with these Payment Institutions to enable them to confirm your payment instruction and complete the receipt of recycling payments. “Affiliates” refer to any company, organization, or legal representative thereof that currently or in the future controls, is controlled by, or is under common control with a party. “Control” means directly or indirectly having the ability to influence the management of the mentioned company, whether through ownership, voting shares, contracts, or other means recognized by the people's court.
- (4) Product or service delivery function:
When you choose to agree to IMPROVED recycling, you need to place a shipping order through IMPROVED and its affiliates or third-party delivery companies cooperating with IMPROVED (including SF Express, hereinafter referred to as “Delivery Companies”), and the third-party delivery company will complete the order pickup for you. You acknowledge and agree that IMPROVED, its affiliates, or third-party delivery companies cooperating with IMPROVED will use your order information during the above process to ensure the safe pickup of your product.
- (5) Customer service function:
Our phone customer service will use your order information. To ensure the security of your account, our customer service will verify your identity using your account information. When you require customer service related to your order information, we will query your order information. You may provide information beyond the above during communication with our customer service, such as when you request us to change the shipping address, contact person, or contact phone number.
- 3. Functions necessary to improve services
We may obtain other information from you based on reasonable needs to provide or improve service quality, including information you provide when contacting customer service, responses you send us when participating in surveys, and relevant information we obtain from interactions between you and our affiliates or partners. For information collected from your various devices, we may associate them to provide you with a consistent service experience across these devices. We may combine information originating from one service with information from other services to provide you with services, content, or recommendations.
- 4. Functions necessary to ensure transaction security
Due to the particular nature of second-hand transactions, in order to ensure transaction security, we may require you to provide your personal identification information (such as ID card, passport, Mainland Travel Permit for Hong Kong and Macau residents, or Five-year Mainland Travel Permit for Taiwan residents), depending on the transaction method. If you refuse to provide the above information, the transaction may not be completed, but it will not affect your ability to browse our services.
In addition, to enhance the security of our services, ensure the safety of the operating environment, detect abnormal account status, better protect the personal and property safety of you, other users, or the public, and more effectively prevent risks such as phishing websites, fraud, network vulnerabilities, computer viruses, cyberattacks, and intrusions, as well as to more accurately identify violations of laws, regulations, or IMPROVED-related agreements/rules, we may, with your authorization, collect your device information. This includes the attributes, connection, and status of the device you use, such as device model, device identifiers
(e.g., IMEI/android ID/IDFA/OPENUDID/GUID/OAID, SIM card IMSI, ICCID information, etc.), device MAC address, software list, telecom operator, and other software and hardware characteristic information.
- (I) Situations where you may voluntarily choose to provide personal information
- 1. To make your second-hand electronic product transactions more convenient or enjoyable and thereby enhance your online transaction experience, our extended optional features may collect and use your personal information. If you choose not to provide this personal information, you can still conduct online transactions; however, you may not be able to use the extended features that enhance the transaction experience or may need to repeatedly enter certain information during transactions. These extended features include:
- (1) Location-based additional services: When you enable the location feature on your mobile device and use services based on your location, we will collect and use your location information to determine your current location and match you with local third-party delivery personnel who can provide door-to-door pickup services.
- (2) Additional services for accessing and uploading photos/videos based on the photo album (image/video library): When you enable photo album access, you can use this function to upload your photos/images/videos in order to display details of the items for recycling and obtain an accurate price estimate.
- 2. The above extended features may require you to enable location and photo album (image library) access permissions on your device so that we can collect and use the information involved in these functions. Please note that enabling these permissions means you authorize us to collect and use such personal information to implement the corresponding functions. Disabling these permissions means you revoke this authorization, and we will no longer collect or use the related personal information, nor will we be able to provide the corresponding features based on those permissions. Your decision to disable permissions will not affect the processing of personal information that was carried out based on your prior authorization.
- (II) You fully understand that in the following situations, we may collect and use your personal information without your consent:
- 1. When it is related to national security or national defense security;
- 2. When it is related to public security, public health, or major public interests;
- 3. When it is related to criminal investigation, prosecution, trial, and enforcement of judgments;
- 4. When it is necessary to protect the life, property, and other major legitimate rights and interests of the personal information subject or other individuals, and it is difficult to obtain their consent;
- 5. When the personal information involved has been publicly disclosed by the personal information subject or their guardian;
- 6. When your personal information is collected from legally disclosed public information, such as lawful news reports, government information disclosures, etc.;
- 7. When it is necessary to sign or perform a contract at your request;
- 8. When it is necessary to ensure the safe and stable operation of the products/services we provide, such as identifying and handling faults in products/services;
- 9. When it is necessary for legitimate news reporting;
- 10. When it is necessary for academic research institutions to conduct statistical or academic research based on public interest, and the results provided to the public have been de-identified for any personal information involved;
- 11. Other circumstances as provided by laws and regulations.
- (III) Situations in which we obtain your personal information from third parties
We may obtain your authorized shared account information (such as profile picture and nickname) from third parties, and upon your consent to this Privacy Policy, bind your third-party account to your IMPROVED account so that you can directly log in and use our products/services via the third-party account. We will confirm the legality of the source of personal information according to agreements with third parties and, under the premise of compliance with relevant laws and regulations, use your personal information accordingly.
- (IV) Rules for the Use of Your Personal Information
- 1. We will use the personal information collected in accordance with the provisions of this Privacy Policy to achieve the functions of our products/services.
- 2. After collecting your personal information, we will use technical means to de-identify the information, and the de-identified information will not be able to identify the subject. Please understand and agree that, under such circumstances, we have the right to use the de-identified information; and without disclosing your personal information, we have the right to analyze the user database and commercially utilize the results.
- 3. Please understand and agree that all personal information you provide while using our products/services will be considered as continuously authorized for our use during your use of the products/services, unless you delete it or refuse our collection through system settings. When you cancel your account, we will stop using and delete your personal information.
- 4. We will collect statistics on the usage of our products/services and may share these statistical data with the public or third parties to demonstrate overall usage trends of our products/services. However, these statistics do not contain any personally identifiable information about you.
- 5. When displaying your personal information, we will use methods such as content replacement and anonymization to desensitize your information and protect its security.
- 6. When we intend to use your personal information for purposes not specified in this Privacy Policy, or when personal information collected for a specific purpose is used for other purposes, we will obtain your explicit consent in advance. Please understand that the products/services we provide may be continuously updated and changed. If you choose to use other products/services not yet listed in this Privacy Policy, we will inform you of the purpose, method, and scope of information collection and seek your consent through announcements, page prompts, or other means before collecting your personal information.
- II. How We Use Cookies and Similar Technologies
- (1) Use of Cookies
- 1. To fulfill your personalized online experience needs and provide you with an easier access experience, we send one or more small data files called Cookies to your computer or mobile device. The Cookies assigned to you are unique and can only be read by the web server in the domain that issued the Cookies to you. We send Cookies to simplify your repeated login process, store your preferences or other product information data to provide you with transaction preferences, help optimize your choice and interaction with advertisements, assist in determining your login status, and ensure the security of your account or data.
- 2. We will not use Cookies for any purposes other than those described in this Privacy Policy. You can manage or delete Cookies according to your preferences. You may clear all Cookies stored on your computer. Most web browsers automatically accept Cookies, but you can usually modify your browser settings to reject Cookies if you wish. Additionally, you can clear all Cookies stored within software. However, if you do so, you may need to manually change user settings each time you visit the IMPROVED website, and previously recorded information will be deleted, which may also affect the security of the services you use.
- (2) Use of Network Beacons and Similar Technologies
In addition to Cookies, we may also use other similar technologies such as web beacons on our website. Our webpages often contain electronic images called "single-pixel" GIF files or "web beacons." The ways we use web beacons include:
- 1. By using web beacons on the IMPROVED website, we count the number of user visits and identify registered IMPROVED users through access cookies.
- 2. Using the obtained cookie information to provide you with personalized services.
- III. How We Share, Transfer, and Publicly Disclose Your Personal Information
- (1) Sharing
- 1. We will not share your personal information with any companies, organizations, or individuals outside of IMPROVED, except in the following situations:
- (1) After obtaining your explicit consent or authorization in advance;
- (2) When required to provide information according to applicable laws and regulations, legal procedures, or mandatory administrative or judicial requests;
- (3) Within the scope permitted by laws and regulations, when it is necessary to provide information to protect the interests, property, or safety of IMPROVED, its affiliates or partners, you, other IMPROVED users, or the general public from harm;
- (4) Only by sharing your information can we realize the core functions of our products/services or provide the services you need;
- (5) To handle disputes or conflicts between you and others at your request;
- (6) In accordance with relevant agreements signed with you (including electronic agreements signed online and corresponding rules) or other legal documents;
- (7) Use based on compliance with laws and regulations for social public interest.
- 2. We may share your personal information with our affiliates. However, we will only share the personal information necessary to provide services, and it will be subject to the purposes stated in this Privacy Policy. If our affiliates intend to change the purpose of processing personal information, they will seek your authorization again.
- 3. We may share your order information, account information, device information, and location information with partners and other third parties to ensure the smooth completion of the services provided to you. However, we will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and only the personal information necessary to provide the products/services. Our partners are not authorized to use the shared personal information for any other purposes. Our partners include the following types:
- (1) Suppliers, service providers, and other partners. Some of our services are provided by business partners solely to achieve the purposes stated in this Policy. For example, to ensure smooth service completion, we may share your personal information with the aforementioned partners, including delivery services, technical services, payment services, etc. This may include your contact information, order information, payment information, address information, and so forth. For instance, when you use logistics and delivery-related functions, we must share your order and delivery information with delivery service providers to ensure safe and accurate delivery; when you use services provided by third-party service providers, we need to provide your order and contact information to these third parties to ensure they can smoothly provide services to you; we also need to share your order number and order amount with third-party payment institutions to confirm your payment instructions and complete the payment.
We share information with suppliers, service providers, and other partners who support our business, including those entrusted to provide technical infrastructure services, customer service, payment facilitation, or conduct academic research and surveys. Please be aware that we only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes. For companies, organizations, and individuals with whom we share personal information solely to achieve the purposes stated in this Policy, we sign strict information protection and confidentiality agreements requiring them to comply with the agreements and take relevant security measures to protect your personal information.
- (2) Promotion partners entrusted by us ("Promotion Partners"). Sometimes we provide promotional services on behalf of other companies to the user groups using our services. We may share with Promotion Partners indirect user profiles formed from your personal information and aggregated non-personal information. However, we only provide these Promotion Partners with information about the reach and effectiveness of promotions and do not provide your personal identification information or aggregate these details in a way that can identify you personally. For example, we may inform Promotion Partners of the number of people who viewed the promotional information or purchased products/used services after viewing it, or provide Promotion Partners with anonymized statistical information to help them understand their audience or customers.
- 4. For the companies, organizations, and individuals with whom we share personal information, we sign strict confidentiality agreements requiring them to handle personal information according to our instructions, this Privacy Policy, and any other related confidentiality and security measures. Regarding the use of sensitive personal data, we require third parties to adopt data anonymization and encryption technologies to better protect sensitive personal information.
- 5. To comply with laws, enforce or apply our Terms of Use and other agreements, or to protect the rights, property, or safety of IMPROVED, you, or other IMPROVED customers—such as preventing fraud and reducing credit risks—we may exchange information with other companies and organizations. However, this does not include selling, renting, sharing, or otherwise disclosing personal information for profit in violation of the commitments made in this Privacy Policy.
- (2) Transfer
We will not transfer your personal information to any companies, organizations, or individuals, except in the following situations:
- 1. After obtaining your explicit consent or authorization in advance;
- 2. When required to provide information according to applicable laws and regulations, legal procedures, or mandatory administrative or judicial requests;
- 3. Provided in accordance with relevant agreements signed with you (including electronic agreements signed online and corresponding website rules) or other legal documents;
- 4. In cases of mergers, acquisitions, asset transfers, or similar transactions, if personal information transfer is involved, 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 that company or organization to obtain your authorization and consent again.
- (3) Public Disclosure
We will only publicly disclose your personal information under the following circumstances and on the premise that industry-standard security protection measures are taken:
- 1. Disclose the personal information you specify according to your request and with your explicit consent to the method of disclosure;
- 2. In situations where laws, regulations, administrative enforcement, or judicial requirements mandate the provision of your personal information, we may disclose your personal information according to the type and method of disclosure required. Under the premise of complying with laws and regulations, when we receive such requests for disclosure, we will require the relevant parties to provide corresponding legal documents, such as subpoenas or investigation letters. We carefully review all requests to ensure they have a legal basis and are limited to data lawfully accessible to enforcement agencies for specific investigative purposes. To the extent permitted by law, the disclosed documents are protected by encryption keys.
- IV. How We Protect and Store Your Personal Information
- (1) Our Technologies and Measures for Protecting Your Personal Information
We take all reasonable and feasible measures to protect your personal information:
- 1. Data Security Technical Measures
We adopt industry-standard security protection measures, including establishing reasonable institutional norms and security technologies to prevent unauthorized access, use, or modification of your personal information, and to avoid data damage or loss. IMPROVED’s online services use encryption technologies such as Transport Layer Security (TLS) protocols and provide browsing services through HTTPS to ensure the security of user data during transmission. IMPROVED encrypts users’ personal information for secure storage and isolates it through isolation technologies.
- 2. Other Security Measures Taken by IMPROVED to Protect Personal Information
IMPROVED manages and regulates the storage and use of personal information by establishing data classification and grading systems, data security management standards, and data security development standards. IMPROVED implements comprehensive data security control through confidentiality agreements, management systems, and other mechanisms.
- 3. We only allow employees and partners of IMPROVED and its affiliates who need to know this information to access personal information, and have established strict access control and monitoring mechanisms for this purpose. We also require all personnel who may come into contact with your personal information to fulfill corresponding confidentiality obligations. Failure to fulfill these obligations may result in legal liability or termination of cooperation with IMPROVED.
- 4. We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected.
- 5. The Internet is not an absolutely secure environment, and communication methods such as email, instant messaging, and social software with other users cannot guarantee complete encryption. We recommend that you use complex passwords when using such tools and pay attention to protecting the security of your personal information.
- 6. Security Incident Handling
When conducting online service transactions with third parties through the IMPROVED website, you will inevitably disclose personal information to the transaction counterpart or potential transaction counterpart. Please properly protect your personal information and only provide it to others when necessary.
To address potential risks such as personal information leakage, damage, and loss, IMPROVED has developed an emergency response plan. Once a personal information security incident occurs, we will promptly inform you in accordance with legal and regulatory requirements about: the basic situation and possible impact of the security incident, the measures we have taken or will take to handle it, recommendations for you to independently prevent and reduce risks, and remedial measures for you. We will also notify you in a timely manner via email, letter, phone, push notifications, etc. If it is difficult to inform each personal information subject individually, we will adopt reasonable and effective methods to publish announcements. At the same time, we will proactively report the handling of personal information security incidents to regulatory authorities as required.
- 7. The internet environment is not 100% secure, and we will do our best to ensure the security of the information you send to us. If our physical, technical, or managerial protective facilities are compromised, resulting in unauthorized access, public disclosure, alteration, or destruction of information and causing damage to your legitimate rights and interests, we will bear the corresponding legal responsibilities.
- 8. If you have any questions about our personal information protection, you may contact us through the contact methods specified in this Privacy Policy. If you discover that your personal information has been leaked, especially if your account and password have been compromised, please contact us immediately through the contact methods specified in this policy so that we can take appropriate measures.
- (2) Retention of Your Personal Information
- 1. Your personal information will be stored within the territory of the People's Republic of China. If you use cross-border transaction services and it is necessary to transfer your personal information abroad to complete the transaction, we will obtain your separate authorization and require the recipient to handle this personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.
- 2. During your use of our products/services, your personal information will be retained for the period necessary to achieve the purposes stated in this policy, and will be managed in accordance with relevant retention period provisions in laws and regulations, such as the "E-commerce Law of the People's Republic of China," which requires that goods and service information and transaction information be kept for no less than three years from the completion date of the transaction. After the retention period expires, we will delete your personal information or anonymize it in accordance with applicable laws.
- 3. If we terminate the service or operations, we will notify you at least thirty days in advance and will delete or anonymize your personal information after the termination of the service or operations.
- V. How You Manage Your Personal Information
IMPROVED strives to protect your rights to access, correct, delete, and withdraw consent regarding your personal information, so that you have full ability to safeguard your privacy and security. You have the following rights:
- 1. Access and Correction of Your Personal Information
Except as provided by laws and regulations, you have the right to access and correct your personal information at any time, including your account information, address information, order information, review information, etc. For information that you cannot access or correct, please contact us.
- 2. Deletion of Your Personal Information
In the following circumstances, you may request us to delete your personal information:
- (1) If our processing of personal information violates laws and regulations;
- (2) If we collect or use your personal information without obtaining your consent;
- (3) f our processing of personal information violates the agreement with you;
- (4) If we terminate the service and operations.
If we decide to respond to your deletion request, we will also notify the entities that obtained your personal information from us to promptly delete it, unless otherwise required by laws and regulations or these entities have obtained your separate authorization. If we respond to your deletion request, we cannot guarantee immediate deletion of the corresponding information from backup systems but will delete the information when the backup systems are updated.
- 3. Change the Scope of Your Authorized Consent or Withdraw Your Authorization
You can change the scope of your authorization for us to continue collecting personal information or withdraw your authorization by contacting IMPROVED customer service.
Please understand that each business function requires some basic personal information to be completed. After you withdraw your consent or authorization, we will no longer be able to provide the services corresponding to the withdrawn consent or authorization, nor process your corresponding personal information. However, your decision to withdraw consent or authorization will not affect the processing of personal information carried out based on your prior authorization.
After you cancel your account, we will cease providing services to you. In accordance with your request and except as otherwise stipulated in this Privacy Policy or required by laws and regulations, we will delete your personal information
If you are unable to access, correct, or delete your personal information through the provided methods, or need to handle other personal data generated while using our products/services, or believe iFengPai has violated any laws, regulations, or agreements regarding personal information collection/use, you may contact us as specified in this Policy. For security purposes, we may require a written request or identity verification before processing, and will respond promptly after verification. Reasonable requests are generally free, but repeated/excessive requests may incur fees. We reserve the right to refuse unfounded, overly repetitive, technically burdensome (e.g., requiring new system development), risky to others' rights, or impractical requests (e.g., involving backup tape data).
In the following circumstances, we will be unable to fulfill your request in accordance with legal and regulatory requirements:
- (1) Related to national security or defense security;
- (2) Related to public safety, public health, or significant public interests;
- (3) Related to criminal investigation, prosecution, or trial;
- (4) Where there is sufficient evidence of your subjective malice or abuse of rights;
- (5) Where fulfilling your request would severely harm your or others' legitimate rights and interests.
- VI. Protection of Minors' Personal Information
- 1. IMPROVED attaches great importance to the protection of minors' personal information. If you are a minor under the age of 18, you should obtain prior written consent from your guardian before using our services. IMPROVED protects the personal information of minors in accordance with applicable national laws and regulations
- 2. For personal information of minors collected with the consent of their parents or legal guardians, we will only use or disclose such information when permitted by law, with explicit consent from the parents or guardians, or when it is necessary to protect the minor.
- 3. If it is proven that a minor has registered for and used our products/services without the consent of their guardian, we will communicate with the relevant guardian and make efforts to delete the related personal information as soon as possible.
- 4. For personal information of children under the age of 14 that may be involved, we will take the following additional measures to ensure its protection:
- (1) In addition to complying with the provisions of this Privacy Policy regarding users' personal information, we will also adhere to the principles of legitimacy and necessity, informed consent, clear purpose, security safeguards, and lawful use when handling the personal information of children. We will strictly follow the requirements of laws and regulations such as the Regulations on the Cyber Protection of Children's Personal Information in storing, using, and disclosing such information. The information will not be retained longer than necessary to fulfill the purposes for which it was collected and used. Upon expiration of that period, we will delete or anonymize the children's personal information. A designated person will be responsible for matters related to the protection of children's personal information.
- (2) When you, as a guardian, choose to use IMPROVED's related services on behalf of the child under your guardianship, we may need to collect the child’s personal information in order to fulfill the necessary requirements of the relevant services. In specific services where children's personal information is required, we will obtain your prior authorization and inform you of the purpose and intended use of the collected information. If you do not provide the requested information, you may not be able to access certain services we offer. In addition, when using features such as product sharing, reviews, or Q&A, you may voluntarily provide us with children’s personal information. Please be fully aware of this and make careful decisions. As a guardian, you are responsible for properly fulfilling your guardianship duties and protecting the security of children’s personal information. If the child needs to register for or use our products/services, you should provide proper guidance and supervision.
- (3) Children or their guardians have the right to access and correct the child's personal information at any time, and may also submit requests to us for correction or deletion. If you have any opinions, suggestions, complaints, or reports regarding children's personal information, please contact us.
- VII. Notification and Revisions
- 1. To provide you with better services and keep up with the development of IMPROVED’s business, this Privacy Policy will be updated accordingly. However, without your explicit consent, we will not reduce the rights you are entitled to under this Privacy Policy. We will publish updated versions on the IMPROVED website and mobile platforms, and notify you of relevant updates before they take effect through website announcements or other appropriate means. We also encourage you to visit IMPROVED regularly to stay informed of the latest Privacy Policy.
- 2. For significant changes, we will also provide more prominent notifications (including but not limited to email, SMS, or special prompts on browsing pages) to explain the specific changes to the Privacy Policy.
- 3. Significant changes referred to in this Privacy Policy include but are not limited to:
- (1) Significant changes in our service model, such as the purpose of processing personal information, the types of personal information processed, and the ways personal information is used;
- (2) Significant changes in our ownership structure, organizational structure, etc., such as ownership changes caused by business adjustments, bankruptcy, mergers, and acquisitions;
- (3) Changes in the main parties with whom personal information is shared, transferred, or publicly disclosed;
- (4) Changes in the department responsible for handling personal information security, contact information, or complaint channels;
- (5) Significant changes in your rights related to the processing of personal information and the methods by which you exercise those rights;
- (6) When the personal information security impact assessment report indicates the presence of high risks.
- VIII. How to Contact Us
- 1. If you have any questions, opinions, or suggestions regarding this Privacy Policy or matters related to your personal information, please contact us through IMPROVED’s online customer service system or by calling our customer service hotline. We will respond to your request within a reasonable time after receiving it.
- 2. If you are not satisfied with our response, especially if our handling of personal information has harmed your legitimate rights and interests, you may also file a complaint or report with regulatory authorities such as the Cyberspace Administration, telecommunications, public security, or industry and commerce departments.