個人情報保護方針

HANGZHOU SUNBA TECHNOLOGY CO.,LTD  (“SUNBA”, “we”, “ours” or “us”) takes your personal information very seriously. This Privacy Policy (“Policy”) has been designed to inform you how SUNBA collects, stores, uses and shares your personal information within its application scope. Please review this Policy before using related SUNBA websites.

The Policy may be modified from time to time and will be posted on this page.

This Policy is applicable to all SUNBA websites that link to it (collectively, the “Site”). For certain functions or services of our Site, additional privacy notice or addendums for such functions or services may apply. SUNBA websites may contain links to third party websites. Your personal information might be collected by third parties when you are using their services; therefore, SUNBA encourages you to learn about the privacy practices of those third parties.

If the personal information you submitted to us contains other individuals’ information, you warrant that you have obtained the approval of such individuals.

By accessing the Site, you acknowledge that you have agreed to our process of your personal information in accordance with the Policy.

Collection of your information

When you use the Site, SUNBA may collect certain information about you as described in this Policy. The information can be divided into information that you provide and information that SUNBA collects. As permitted by applicable laws or after obtaining your prior consent, we may further collect personal information that is necessary for your use of the Services from third parties.

Personal information that we collect depends on your use of the Service. For example,

• When you visit the Site, we may collect the traffic data, e.g. IP address and information through cookies, including the visitor volume, access time, and user preference.
• When you register an account on the Site, you may need to provide registration information, like your name, phone number, email address, your company, your country or region, etc.
• When you look for cooperation with SUNBA, you may provide your contact information.  

Use of personal information

SUNBA uses your personal information for the following purposes:

• For SUNBA’s legitimate interest, namely:
• to respond to your inquiries;
• to increase the safety of the Services, such as user authentication, security protection, fraud detection, filing and backups;
• to proceed any activities you subscribed on the Services; or

for internal purposes, such as auditing, data analysis, and research.

• To perform the agreement we have with you, for example:

to provide other services you request;

• To meet SUNBA’s legal obligations,

• With your consent,
• to send electronic communications to tell you about new products and services;
• to use certain non-essential cookies to better understand your behavior, in order to optimize user experience, perfect function design, or to provide better services; or
• We may also engage one or more third party service providers to serve online advertisements on our behalf via the Services. They may use a pixel tag or other similar technology to collect information about your visit to the Services, and they may use that information to target advertisements for SUNBA products and services.

Sharing of personal information

We do not sell any personal information to third parties and we never will.

SUNBA will not disclose your personal information, unless (I) with your prior written consent; (II) in accordance with the applicable laws and regulations, or where required by competent authorities; (III) as required to offer the Services; or (IV) to protect its legitimate interests, for example, to defend its rights on administrative or judicial procedures or in case its business or parts thereof is transferred to sold to another party.

SUNBA limits access to your personal information on a need-to-know basis, and requires its employees to respect the confidentiality of your information and protect your information in accordance with the Policy.

Storage and security of personal information

SUNBA stores your personal information for as long as required to provide the Services or respond to your questions. Other information will be retained for no longer than is necessary for the purposes stated in this Policy, unless otherwise requested by user or permitted by law.

We have implemented commercially reasonable administrative, technical, and physical security controls that are designed to safeguard personal information. We also conduct periodic reviews and assessments of the effectiveness of our security controls.

Notwithstanding the above, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, SUNBA cannot guarantee that your personal information is under absolute security with the existing security technology.

Transfer of personal information outside of your jurisdiction

To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies or Third Party Service Providers, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You will have the right to be informed of the appropriate safeguards taken by SUNBA for this transfer of your personal information.

SUNBA is a China-headquartered company operating globally. As such, complying with applicable laws, we may transfer your personal information to our third party service providers, who may be located in a country or area outside the area of the European Economic Area (EEA).

Whenever SUNBA shares personal information originating in the EEA with a third party which may or may not be a SUNBA entity outside the EEA, we will do so on the basis of EU standard contractual clauses or any other safeguards provided for in the GDPR.

Currently, SUNBA has data center in Hangzhou. You have understood that the risks under applicable data protection laws are different and we may transfer to and store your personal information at our overseas facilities. However, this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Policy.

Your rights

SUNBA generally stores your personal information on SUNBA’s servers until you delete or edit it, or for as long as you remain an Account user in order for us to provide you with the most relevant offers.

Keeping your personal information current helps ensure that we provide you with the most relevant offers. You can access, update or delete your personal information via your Account profile. We are ready to assist you in managing your subscriptions, deactivating your account, and removing your active profile and data.

You have the right to object at any time and for reasons derived from your personal situation to our processing of your data on the legal grounds of “legitimate interest”. If you exercise your right of objection, we will stop processing your data unless we can demonstrate compelling legitimate grounds for the processing which override your rights.

We will retain your personal information for the period necessary to fulfill the purpose outlined in this Policy unless a longer retention period is required or permitted by applicable law.

Contact method

If you have questions or concerns about SUNBA’s use of your personal information, you can contact us at: [email protected]. If you still have concerns, you have right to lodge a complaint with the Supervisory Authority for data protection in your country/region.

Last updated: June 2022