Free Conseil 隐私政策
欢迎您访问我们的产品。 Free Conseil （包括网站等产品提供的服务，以下简称“产品和服务”）是由 ECENTIME （以下简称“我们”）开发并运营的。 确保用户的数据安全和隐私保护是我们的首要任务， 本隐私政策载明了您访问和使用我们的产品和服务时所收集的数据及其处理方式。
请您在继续使用我们的产品前务必认真仔细阅读并确认充分理解本隐私政策全部规则和要点， 一旦您选择使用，即视为您同意本隐私政策的全部内容，同意我们按其收集和使用您的相关信息。 如您在在阅读过程中，对本政策有任何疑问，可联系我们的客服咨询， 请通过 contactus@freeconseil.com 或产品中的反馈方式与我们取得联系。 如您不同意相关协议或其中的任何条款的，您应停止使用我们的产品和服务。
本隐私政策帮助您了解以下内容：
一、我们如何收集和使用您的个人信息；
二、我们如何存储和保护您的个人信息；
三、我们如何共享、转让、公开披露您的个人信息；
四、我们如何使用 Cookie 和其他追踪技术；
一、我们如何收集和使用您的个人信息
个人信息是指以电子或者其他方式记录的能够单独或者与其他信息， 结合识别特定自然人身份或者反映特定自然人活动情况的各种信息。 我们根据《中华人民共和国网络安全法》和《信息安全技术个人信息安全规范》（GB/T 35273-2017） 以及其它相关法律法规的要求，并严格遵循正当、合法、必要的原则， 出于您使用我们提供的服务和/或产品等过程中而收集和使用您的个人信息，包括但不限于电话号码、电子邮箱地址、偏好及兴趣等。
为接受我们全面的产品服务，您应首先注册一个用户账号，我们将通过它记录相关的数据。 您所提供的所有信息均来自于您本人在注册时提供的数据。 您准备使用的账户名、密码、您本人的联系方式， 我们可能通过发短信或者邮件的方式来验证您的身份是否有效。
二、我们如何存储和保护您的个人信息
作为一般规则，我们仅在实现信息收集目的所需的时间内保留您的个人信息。 我们会在对于管理与您之间的关系严格必要的时间内保留您的个人信息 （例如，当您开立帐户，从我们的产品获取服务时）。 出于遵守法律义务或为证明某项权利或合同满足适用的诉讼时效要求的目的， 我们可能需要在上述期限到期后保留您存档的个人信息，并且无法按您的要求删除。
当您的个人信息对于我们的法定义务或法定时效对应的目的或档案不再必要时， 我们确保将其完全删除或匿名化。 我们使用符合业界标准的安全防护措施保护您提供的个人信息，并加密其中的关键数据， 防止其遭到未经授权访问、公开披露、使用、修改、损坏或丢失。我们会采取一切合理可行的措施，保护您的个人信息。 我们会使用加密技术确保数据的保密性；我们会使用受信赖的保护机制防止数据遭到恶意攻击。
三、我们如何共享、转让、公开披露您的个人信息
在管理我们的日常业务活动所需要时，为追求合法利益以更好地服务客户， 我们将合规且恰当的使用您的个人信息。出于对业务和各个方面的综合考虑， 我们仅自身使用这些数据，不与任何第三方分享。 我们可能会根据法律法规规定，或按政府主管部门的强制性要求，对外共享您的个人信息。 在符合法律法规的前提下，当我们收到上述披露信息的请求时，我们会要求必须出具与之相应的法律文件，如传票或调查函。 我们坚信，对于要求我们提供的信息，应该在法律允许的范围内尽可能保持透明。
在以下情形中，共享、转让、公开披露您的个人信息无需事先征得您的授权同意：
1、与国家安全、国防安全直接相关的；
2、与犯罪侦查、起诉、审判和判决执行等直接相关的；
3、出于维护您或其他个人的生命、财产等重大合法权益但又很难得到本人同意的；
4、您自行向社会公众公开的个人信息；
5、从合法公开披露的信息中收集个人信息的，如合法的新闻报道、政府信息公开等渠道。
6、根据个人信息主体要求签订和履行合同所必需的；
7、用于维护所提供的产品或服务的安全稳定运行所必需的，例如发现、处置产品或服务的故障；
8、法律法规规定的其他情形。
四、我们如何使用 Cookie 和其他追踪技术
为确保产品正常运转，我们会在您的计算机或移动设备上存储名为 Cookie 的小数据文件。 Cookie 通常包含标识符、产品名称以及一些号码和字符。 借助于 Cookie，我们能够存储您的偏好或商品等数据，并用以判断注册用户是否已经登录， 提升服务和产品质量及优化用户体验。
我们出于不同的目的使用各种Cookie，包括：严格必要型Cookie、性能Cookie、营销Cookie和功能Cookie。 某些Cookie可能由外部第三方提供，以向我们的产品提供其它功能。
我们不会将 Cookie 用于本政策所述目的之外的任何用途。您可根据自己的偏好管理或删除 Cookie。 您可以清除计算机上或手机中保存的所有 Cookie，大部分网络浏览器都设有阻止或禁用 Cookie 的功能， 您可对浏览器进行配置。阻止或禁用 Cookie 功能后，可能影响您使用或不能充分使用我们的产品和服务。
ECENTIME SAS PRIVACY NOTICE (GDPR COMPLIANT)
This Policy is only applicable to ECENTIME’s products or services of Shanxi ShengYuanChangYi Network Technology Co.,LTD. The main business is online shopping guide including ECENTIME’s applications and website services: http://www.ecentime.com.
Last updated [November, 2021]
If you have any questions, please contact us:
Shanxi Fahua Network Technology Co.,LTD (collectively referred to as “ECENTIME”, “we”, “us” or “our” in this privacy notice) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website or mobile application (the “Platforms”)(regardless of where you visit it from) and use our services and tells you about your privacy rights and how the law protects you.
I. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how ECENTIME collects and processes your personal data through your use of the Platforms and engaging our services, including any data you may provide through the Platforms or by other means.
The Platform is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements our other notices and policies and is not intended to override them.
Controller
ECENTIME is the controller and responsible for your personal data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the DPO using the details set out below.
Contact details
Our full details are:
Full name of legal entity: ECENTIME SAS
Contact Person: Project Manager
Email address: contactus@freeconseil.com
Postal address:1 Parvis de la Défense, 92044 Puteaux France
You have the right to make a complaint at any time to the Commission nationale de l'informatique et des libertés (CNIL), the France supervisory authority for data protection issues (https://www.cnil.fr/). We would, however, appreciate the chance to deal with your concerns before you approach the CNIL so please contact us (our contact details are set out above) in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on the date as shown at the bottom of this privacy notice. Historic versions can be obtained by contacting us (our contact details are set out above).
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our Platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platforms, we encourage you to read the privacy notice of every website you visit.
If you agree, we will share your data with our partner companies so that they may offer you their products and services.
List of organizations that will receive data:
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ALIPAY:https//render.alipay.com/p/c/k2cx0tg8
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TENCENT:https://weixin.qq.com/cgi-bin/readtemplate?lang=zh_CN&t=weixin_agreement&s=privacy
II. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Contact Data includes your email or a social media account of yours for registration.
• Identity Data includes your chosen username, gender, your chosen photograph and your location.
• Marketing and Communications Data includes your preferences regarding the marketing materials and information that you receive from us and our third parties and your communication preferences.
• Profile Data includes your interests, preferences (favourite brands and deals), feedback and survey responses.
• Technical Data includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, heat map, operating system and platform and other technology on the devices you use to access our Platforms.
• Usage Data includes information about how you use our Platforms, products and services.
We also collect, use and share data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your and others’ Profile Data to calculate the percentage of users that have a specific preference. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
III. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
subscribe to our service or publications (for example, newsletter and push notifications);request marketing to be sent to you;enter a competition, promotion or survey; make a transaction on our site or our partner’s website;give us some feedback.
• Automated technologies or interactions. As you interact with our Platforms, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy below.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
· Technical Data analytics providers such as Google, Apple, Baidu and others based outside the EU;
· Contact Data from providers of technical services.
· Identity and Contact Data from data brokers or aggregators.
· Identity and Contact Data from publicly available sources such as Companies House and the Electoral
· Register based inside the EU.
IV. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us (our contact details are set out above).
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us (our contact details are set out above) if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). The cookies are used for personalized ads or content.
You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us (our contact details are set out above).
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service experience.
Cookies
Our Platforms use cookies to distinguish you from other users of our Platforms. This helps us to provide you with a good experience when you browse our Platforms and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Platforms when they are using them. This helps us to improve the way our Platforms work, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognize you when you return to our Platforms. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our Platforms, the pages you have visited and the links you have followed. We will use this information to make our Platforms and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (our contact details are set out above).
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
V. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table
in paragraph 4 above.
• External Third Parties as set out in the glossary below.
• Specific third parties that will provide you with a good or service.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
VI. International transfers
We have employees based in China, who have access to the personal data.Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it.
VII. Data security
We store all data on the server we have with Amazon Relational Database Service (Amazon RDS)(https://aws.amazon.com/cn/).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
VIII. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us (our contact details are set out above).
By law we have to keep basic information about our customers (including Contact and Identity Data) for six years after they cease being customers for tax purposes.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
IX. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us (our contact details are set out above).
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
X. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us (our contact details are set out above).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.