Phoenix Universal personal information protection policy

This policy is only applicable to Phoenix Universal app of country garden.

Last updated: August 2020.

If you have any questions, comments or suggestions, please contact us through the following contact information:

(1) Daily contact information (preferred): Phoenix Communication Department of brand marketing centerbgyfht@countrygarden.com.cn Daily office address: Country Garden Center, Beijiao Town, Shunde District, Foshan City, Guangdong Province (2) If the problem cannot be solved by the above methods, an email can be sent to DPO@countrygarden.com.cn. Contact the data protection and compliance office. Office address: Country Garden Center, Beijiao Town, Shunde District, Foshan City, Guangdong Province

This policy will help you understand the following:

How do we collect and use your personal information

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

How do we protect your personal information

Your rights

How do we process personal information about minors

How is your personal information transferred globally

How to update this policy

How to contact us

Country Garden Phoenix knows the importance of personal information to you, and will do its best to protect your personal information safe and reliable. We are committed to maintaining your trust in US and protecting your personal information in accordance with the following principles: the principle of consistent rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the principle of minimum sufficiency, the principle of ensuring security, the principle of subject participation, and the principle of openness and transparency. At the same time, country garden Phoenix promises that we will take corresponding security protection measures to protect your personal information according to the mature security standards of the industry.

Please read and understand this policy carefully before using our products (or services).

1、 How do we collect and use your personal information

Personal information refers to all kinds of information recorded by electronic or other means, which can identify the identity of a specific natural person or reflect the activities of a specific natural person alone or in combination with other information.

Country Garden Phoenix Universal will only collect and use your personal information for the following purposes as stated in this policy:

(1) Provide personal information for recommending customer business and corresponding business use

Business function one: register as a user.

In order to complete the account creation, you need to provide your mobile phone number as the login account, and Country Garden Phoenix Universal will send SMS verification code to the mobile phone number provided by you to confirm that you have registered.

During the registration process, if you authorize wechat to bind with Phoenix Universal account, choose your own user type, provide ID card information and bank card information, it will help us to provide you with better service and experience. If you do not provide such information, it will not affect the basic business functions of the service.

Business function 2: login.

For your account security, we use the single device login design.

Business function 3: project display.

In order to display the surrounding projects near your location, we will collect your location information, and you need to open the location permission of Phoenix Universal APP. Country Garden Phoenix Universal will not store this information, and refusing to provide this information will not affect your normal browsing of the property. In addition, the display of real estate needs read-write storage rights to display and cache the real estate publicity pictures.

Business function 4: recommend customers to project.

When you use Country Garden Phoenix Universal to promote customers, in order to protect your rights and interests, we will need you to provide your own name and ID card information for real name authentication, and collect the name and mobile phone number of the customer you recommend to determine whether the promotion is successful or not. In order to facilitate the promotion, we will read your address book information after obtaining your explicit authorization. You can select the address book information for quick promotion. Country Garden Phoenix Universal will not store the above sensitive information. If you refuse to provide this information, it will not affect the basic business functions of the service.

Business function 5: invite friends to register.

When you use Country Garden Phoenix Universal to invite customers, in order to protect your rights and interests, we will need you to provide your name and ID card information for real name authentication.

Business function 6: commission payment

When the client you recommend or the client recommended by your invited friends completes the transaction and complies with the activity rules of Phoenix Universal platform and real estate promotion, we will pay you the corresponding Commission according to the activity rules. In order to ensure the normal payment of commission, we need to collect your bank card information, and verify the bank card to ensure that it is your own bank card.

Business function 7: Commission Service

In order to be able to quickly invoice and commission payment, after you agree to the user agreement and privacy agreement of the third party platform, you can authorize the third party to issue invoice and Commission on behalf of the third party. In order to issue legal and compliance tax payment certificate, you need to provide ID card photo information, and you need to access the camera (Pls turn on camera permission). Phoenix Universal will not store this sensitive information. In addition, in order to timely inform you to handle the pending commission information, Country Garden Phoenix Universal will send short messages to your mobile phone number when you register your account.

Authorized partners of the third-party commission service include: cloud account (Tianjin) sharing Economic Information Consulting Co., Ltd., Nanchang UFIDA Xifu society cloud Technology Co., Ltd., fengbi information technology (Haikou) Co., Ltd.

(2) Third party services used (SDK)

a, Aurora SDK

Function: it is used to send message prompt of settlement commission to users (only used for sending message, no advertising or precision marketing function)

Permissions: write to external storage

Turn off: push function can be turned on / off at my settings push switch

b, Tencent SDK

Functions: Tencent map, wechat login, wechat sharing

Access rights: write to external storage, get mobile phone status, read phone number

c, baidu SDK

Function: it is used to locate the current city and provide users with current city property information.

Usage rights: locating permissions

d, cloudwise

Role: end to end application performance management, full link performance pressure testing, real-time big data visualization analysis, continuously improve business operation and IT management efficiency

Usage rights: equipment information (software and hardware feature information such as equipment model, operating system version, etc.), location information of equipment (such as login IP address, GPS location and Wi Fi access point that can provide relevant information), Phoenix Universal software version number, etc.

e,Wdstats / WdUsageStats

Function: collect equipment information and operation log information, and provide more professional dimension business service support for enterprises through real-time and quasi real-time big data processing.

Usage rights: equipment information (device model, operating system version and other software and hardware feature information, equipment location information (such as login IP address, GPS location and Wi Fi access point that can provide relevant information), Phoenix Universal software version number, etc.), log information (operation log, website information, service failure information), display current interface information (Android needs to startUse get_Tasks permissions)

The above information provided by you will continue to be authorized by us during your use of the service. When you cancel your account, we will stop using and delete the above information.

The above information will be stored in the people's Republic of China. For cross-border transmission, we will obtain your authorization and consent separately.

Note that after you agree to the above permissions, it means that we will be able to use the personal information corresponding to the above permissions. When you refuse or close (you can open and close the permissions of the app in the system settings), we will not continue to collect and use your personal information, nor will we indirectly collect and use your personal information through any other illegal channels. At the same time, we may not be able to enjoy these authorized corresponding services provided for you.

We will seek your prior consent when using information for other purposes not specified in this policy.

When we want to use the information collected for a particular purpose for other purposes, we will seek your prior consent.

2、 How can we share, transfer and publicly disclose your personal information

(1) Share

We will not share your personal information with any company, organization or individual other than country garden group, except for the following situations:

a, Sharing with explicit consent: after obtaining your explicit consent, we will share your personal information with other parties.

b, We may share your personal information with the public in accordance with laws and regulations or mandatory requirements of the competent government departments.

c, Sharing with our affiliated companies: with explicit consent, your personal information may be shared with the affiliated companies of Country Garden Holdings Limited. We will only share the necessary personal information and will be subject to the purposes stated in this personal information protection policy. If the affiliated company wants to change the processing purpose of personal information, it will ask for your authorization again.

Our affiliated companies include: Guangzhou Country Garden Phoenix Hotel Management Co., Ltd.

d, Sharing with authorized partners: for the purpose stated in this policy only, some of our services will be provided by authorized partners with explicit consent. We may share some of your personal information with partners to provide better customer service and user experience. We will only share your personal information for legitimate, legitimate, necessary, specific and explicit purposes, and only share personal information necessary to provide services. Our partners do not have the right to use the shared personal information for any other purpose.

At present, our authorized partners include:

① Tianju DIHE (Suzhou) data Co., Ltd. provides ID card real name authentication and bank card information verification services.

② Cloud account (Tianjin) sharing Economic Information Consulting Co., Ltd. provides commission service.

③ Nanchang yonyou Xifu social cloud Technology Co., Ltd. provides commission service.

④ Fengbi information technology (Haikou) Co., Ltd. provides commission service.

In addition, Country Garden Phoenix Universal will share your account information with Country Garden Phoenix cloud, so as to facilitate you to better use Phoenix Universal commission service and Phoenix cloud partner service (if any).

We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share personal information, requiring them to process personal information in accordance with our instructions, this personal information protection policy and any other relevant confidentiality and security measures.

(2) Assignment

We will not transfer your personal information to any company, organization or individual except:

a, Transfer with explicit consent: after obtaining your explicit consent, we will transfer your personal information to other parties;

b, After anonymization of your personal information, we can transfer the processed information to other parties;

c, In case of merger, acquisition or bankruptcy liquidation, 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 personal information protection policy; Otherwise, we will require the company or organization to seek your authorization and consent again.

(3) Public disclosure

We will only disclose your personal information in the following circumstances:

a, After obtaining your explicit consent;

b, Disclosure based on Law: we may disclose your personal information publicly under the circumstances of laws, legal procedures, litigation or mandatory requirements of government authorities.

3、 How do we protect your personal information

(1) We have used industry standard security measures to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable and feasible measures to protect your personal information. For example, we encrypt the data; at the same time, we use HTTPS to access the server or web page security methods; our app will use encryption technology to ensure the confidentiality of data; we will use trusted protection mechanisms to prevent malicious attacks on data; we will deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we will hold security and privacy protection training courses to enhance employees awareness of the importance of protecting personal information.

(2) Country Garden Phoenix Universal attaches great importance to information security and has established a special team in charge. We strive to provide you with information protection, take appropriate management, technical and physical security measures, and establish an information security assurance system suitable for business development by referring to domestic and foreign information security standards and best practices.

(3) We also strictly manage the employees who may come into contact with your information, monitor their operation, establish an approval mechanism for important operations such as data access, internal and external transmission, desensitization and decryption, and sign confidentiality agreements with the above-mentioned employees. At the same time, we also regularly carry out information security training for employees, requiring them to form good operating habits in their daily work and enhance their awareness of data protection. We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for the period required to achieve the purpose stated in this policy, unless the retention period needs to be extended or is permitted by law.

(4) Despite the above security measures, please understand that there is no "perfect security measures" on the network. We will provide corresponding security measures according to the existing technology to protect your information and provide reasonable security protection. We will try our best to prevent your information from being leaked, damaged or lost.

(5) After an unfortunate personal information security incident occurs, we will inform you in a timely manner according to the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions that you can independently prevent and reduce the risk, and the remedial measures for you, etc. We will promptly inform you of the relevant information by email, letter, telephone, push notification, etc. when it is difficult to inform the personal information subject one by one, we will release the announcement in a reasonable and effective way.

At the same time, we will also actively report the disposal of personal information security incidents in accordance with the requirements of regulatory authorities.

4、 Your rights

In accordance with the relevant laws, regulations and standards of China, as well as the common practices of other countries and regions, we guarantee that you exercise the following rights to your personal information:

(1) Access to your personal information

You have the right to access your personal information, except for exceptions provided by laws and regulations. If you want to exercise data access, you can access it yourself in the following ways:

Account information - if you want to access or edit personal information and payment information in your account, change your password, add security information or close your account, you can do this by accessing my settings.

If you do not have access to this personal information through the above links, you can contact us at any time using our web forms or by contacting us through the methods listed on the front page of this article. We will reply to your request within 15 working days.

We will provide you with other personal information generated in the process of using our products or services as long as we do not need to invest too much. If you want to exercise data access, please contact us through the methods listed on the first page of this article.

(2) Correct your personal information

When you find that our personal information about you is wrong, you have the right to ask us to make corrections. You can apply for correction in the way listed in "(1) access to your personal information".

If you are unable to correct personal information through the above links, you can contact us at any time by using our web form or by contacting us through the methods listed on the front page of this article. We will reply to your request for correction within 15 working days.

(3) Delete your personal information

You can request us to delete personal information in the following situations:

a, If we handle personal information in violation of laws and regulations;

b, If we collect and use your personal information without your consent;

c, If our handling of personal information violates the agreement with you;

d, If you no longer use our products or services, or you cancel your account number;

e, If we no longer offer you products or services.

If we decide to respond to your request for deletion, we will also notify the entities that have obtained your personal information from us and ask them to delete them in a timely manner, unless otherwise stipulated by laws and regulations, or if these entities are authorized by you independently.

(4) Change the scope of your authorized consent

Each business function requires some basic personal information to complete (see "part I" of this policy). For the collection and use of additional collected personal information, you can give or withdraw your authorization at any time.

(5) Personal information subject cancels account

You can cancel the previously registered account at any time. You can operate by yourself in the following ways:

After entering my - settings, click Cancel Account. After canceling the account, we will stop providing products or services for you, and delete your personal information according to your requirements, unless otherwise stipulated by laws and regulations.

(6) Personal information subject obtains copy of personal information

You have the right to obtain a copy of your personal information, and you can operate by yourself in the following ways:

On the premise that the technology is feasible, such as data interface matching, we can also directly transfer your personal information copy to the third party designated by you according to your requirements.

(7) Automatic decision making of constraint information system

In some business functions, we may only make decisions based on non manual automatic decision-making mechanisms including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will provide appropriate remedies.

(8) Respond to your above request

For security, you may need to provide a written request or other means to prove your identity. We may ask you to verify your identity before processing your request. We will reply within 15 working days. If you are not satisfied, you can also contact us through the way listed on the front page of this article.

In principle, we will not charge you for your reasonable request, but we will charge a certain cost for repeated requests beyond the reasonable limit. We may reject requests that are unreasonably repetitive, require excessive technical means (e.g., the need to develop new systems or radically change existing practices), pose a risk to the legitimate rights and interests of others, or are highly impractical (e.g., involving information stored on backup tapes).

We will not be able to respond to your request in the following situations:

a, Related to the personal information controller have to follow the obligations stipulated by laws and regulations;

b, Directly related to national security and national defense security;

c, Directly related to public safety, public health and major public interests;

d, Directly related to criminal investigation, prosecution, trial and execution of judgments;

e, The personal information controller has sufficient evidence to show that the personal information subject has subjective malice or abuse of rights;

f, In order to protect the life and property of personal information subject or other individuals, but it is difficult to obtain my consent;

g, Responding to the request of the personal information subject will cause serious damage to the legitimate rights and interests of the personal information subject or other individuals and organizations;

h, Involving trade secrets.

5、 How do we process children’s personal information

Our products, websites and services are mainly for adults. Children are not allowed to create their own user accounts without the consent of their parents or guardians.

For the collection of children’s personal information with the consent of parents, we will only use or disclose such information to the extent permitted by law, with the explicit consent of parents or guardians, or necessary for the protection of children.

Although local laws and customs have different definitions of children, we regard anyone under the age of 16 as a child.

If we find that we have collected personal information about children without the prior consent of verifiable parents, we will try to delete the relevant data as soon as possible.

6、 How is your personal information transferred globally

In principle, the personal information we collect and generate within the People’s Republic of China will be stored in the People’s Republic of China.

With regard to the personal information generated during the use of Phoenix Universal system products and services by Phoenix Universal users outside the People’s Republic of China, you agree to send back and store it on the domestic server under the premise of complying with the laws and regulations of the host country, otherwise you can’t use the existing products and services of Phoenix Universal system normally. In such cases, we will ensure that your personal information is adequately and equally protected within the People’s Republic of China.

7、 How to update this policy

Our personal information protection policy may change.

Without your explicit consent, we will not reduce your rights under this personal information protection policy. We will post any changes to this policy on this page and prompt users to update this agreement when entering app.

For major changes, we will also provide more significant notices (including for some services, we will send notices through app or SMS to explain the specific changes of personal information protection policy).

Major changes referred to in this policy include but are not limited to:

a, Our service model has changed significantly. For example, the purpose of personal information processing, the type of personal information processing, the use of personal information, etc.;

b, Major changes have taken place in our ownership structure and organizational structure. Such as the change of owners caused by business adjustment, bankruptcy and merger, etc.;

c, The main objects of personal information sharing, transfer or public disclosure have changed;

d, There are significant changes in your right to participate in personal information processing and the way in which you exercise it;

e, When the Department responsible for handling personal information security, contact information and complaint channels change;

f, Personal information security impact assessment report indicates that there is a high risk.

We will also file older versions of this policy for your reference.

8、 How to contact us

If you have any questions, opinions or suggestions about this personal information protection policy, you can contact us through the ways listed on the first page of this article.

Generally, we will reply within 15 working days.