Last updated on: 06/08/2023 Effective on: 06/08/2023
AllMyTracks Technology (hereinafter “AllMyTracks Technology” or “we”) is well aware of the importance of personal information security, and respects the information and privacy security of all users (hereinafter “User” or “you”), and will take security protection measures in accordance with laws, regulations and technical specifications to protect the security and control of personal information of users.
THEREFORE, we prepare this Privacy Policy (hereinafter the “Privacy Policy” or “Statement and Privacy”) and remind you that: Before using the products or services of this Website, please be sure to read carefully and understand thoroughly this Privacy Policy, and not use the products or services until confirming that you fully understand and agree to it. Once you start using this website, you will be deemed to have accepted and agreed to the content of this Statement and Policy.
AllMyTracks Technology reminds minors that, should you have no full capacity for civil conduct, please carefully read and fully understand this Privacy Policy in the company of your legal guardians, and use our services or provide us with information only after obtaining the consent of your guardians. We would also like to draw the attention of guardians to the chapter specially made for the protection of minors. Users please read this chapter carefully and decide whether to agree to it or not.
Special Reminder: This Privacy Policy sets forth the general privacy policy terms uniformly adopted by AllMyTracks Technology. For our certain products/services, we may formulate a separate privacy policy or agreement, and Users should fully read and agree to the entire content of such privacy policy or agreement before using such products/services.
Unless otherwise agreed, terms used herein generally shall have the meanings ascribed to them below:
1. Personal Information: refers to all kinds of information, recorded by electronic or other means, that can be used, alone or combined with other information, to identify a particular individual or reflect activities of a particular individual.
2. Personal Sensitive Information: refers to Personal Information which, once leaked, illegally provided or misused may endanger personal and property safety, and easily lead to damage to personal reputation or physical and mental health, or discriminatory treatment..
i. Compared with other Personal Information, Personal Sensitive Information may have a greater impact on the personal rights and interests of Users. We kindly remind Users to provide us with Personal Sensitive Information only after prudent consideration.
3. Authorized Consent: refers to the User's explicit authorization for specific processing of his Personal Information, that is given by affirmative action (i.e. express consent) or negative inaction.
i. Please be aware that Authorized Consent may be expressed as “Authorization” or “Consent” herein.
4. User Profiling: refers to the process of collection, aggregation, and/or analysis of Personal Information to analyze or predict certain personal features relating to the User, such as profession, economic condition, educational background, personal preferences, credit, and behavior, to form a model of certain personal characteristics.
5. Anonymization: refers to the process of technical processing of Personal Information in such a manner that the Personal Information subject cannot be identified or associated and the processed information cannot be de-anonymized. Device: refers to any device that can be used to access our products and/or services, such as PC, laptop, tablet or smart phone.
6. UDID (or unique ID or UUID): refers to a string written to the Device by the Device manufacturer to identify the corresponding Device in an unique way (e.g. IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information, etc.). UDID can be used for a variety of purposes, among which it can be used for advertising purpose when Cookies cannot be used, such as in mobile applications.
7. IP Address: Every Device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP Address can often be used to identify the location from which a Device is connecting to the Internet.
8. SSL: Secure Socket Layer (SSL), is a security protocol implemented on the Transmission Control Protocol/Internet Protocol (TCP/IP). SSL supports various types of networks and provides three basic security services at the same time, all of which use public key and symmetric key cryptographies to achieve the confidentiality of information.
9. Cookies: Cookies are small files containing strings that are sent and stored on the User's computer, mobile Device or other Device (usually encrypted) when the User logs in to and uses a website or other web content. Similar Tracking Technologies are other technologies that can be used for purposes similar to cookies, such as WebBeacon, Proxy, embedded scripting, etc.
10. Account: When a User registers an account and provides us with certain Personal Information, he can better use our services. When a User accesses to our services, the system will use such Account information to authenticate the User to prevent unauthorized persons from accessing the User's Account.
11. Anonymization: The process of technical processing of Personal Information in such a manner that the Personal Information subject cannot be identified or associated and the processed information cannot be de-anonymized.
12. De-identification: The process of technical processing of Personal Information in such a manner that the Personal Information subject cannot be identified or associated without the use of additional information.
13. Server Logs: Generally, our servers automatically record web page requests made when you visit the website. These Server Logs often include the User's network request, Internet Protocol address, browser type, browser language, date and time of the request, and one or more Cookies that uniquely identify the User's browser.
You acknowledge and agree that in your use of the services provided by us, we will collect the information provided by you when using the services or generated from your use of the services in the following ways, and the functions/scenarios in which you are requested to authorize us to collect and use your Personal Information include:
1. When you use the Account registration and login functions, we will collect certain information that you voluntarily provide to us to identify the User, including e-mail, and to create a password. Your password will be automatically stored, transmitted and verified in encrypted form, which will not be stored, transmitted and verified by us in clear text. When storing, entering, or using your password, you should carefully check the physical and electronic environments to prevent password leakage. You should be aware that we collect such information to meet the requirements of applicable laws and regulations only, and that your refusal to provide such information may cause you unable to use our function. Please think carefully before your action.
2. When you log in to any AllMyTracks Technology Account by linking a third-party account for log-in(if any), we will obtain the relevant information under such third-party platform account (including nickname, region, gender and other information) subject to and in accordance with your Authorization. We collect such information to provide you with Account login services, protect the security of your Account and prevent security risks. Should you refuse to authorize such information, you will not be able to use the third-party platform account to log in to our platform, however, this will not affect your normal use of other products and services we offer to Users.
3. Besides, you may also fill in or add the User’s nickname, occupation/industry, personality signature information, gender, birthday, region, educational background, and personal profile information in the [Edit Your Profile] settings at the time of registration or in your subsequent use. Your failure to fill in or subsequent deletion or change of such information may affect our provision (including unavailability) of the content and advertisements of your interest based on your User Profiling information, however, it will not affect your normal use of registration and membership functions (such as enabling a service).
4. When using the services provided by us, in order to help you complete registration and login, we will collect and use the information that you fill in, transmit voluntarily and are willing to be used by us, such as name, email address, etc.
5. In order to ensure the normal use of our services by you, maintain the proper functioning of our products and/or services, optimize the performance of our products and/or services, and improve the experience for you, we will collect certain information from you according to the specific operation of your use of our products and/or services, including the following Personal Information:
(1) Log Information: When you use our services, we may automatically collect information about your personal Internet history and details of your use of our services and save them as a relevant web log. Log information includes your login Account, date and time of access, IP Address, Device information, network environment, network operator information, browsing records, download and use records, play time, associated works, operating system information, software installation information, search engine marketing information and other information provided, generated or retained by you when using our products or services.
(2) Device Information: We may receive and record the MAC address, login IP address, Device manufacturer, Device brand, Device name, Device model, operating system version, Device settings, UDID, Device environment, mobile application list, browser type and settings, language settings, operating system and application version, Internet access method, network quality data, mobile network information (including operator name), and other software and hardware feature information, information about the location of the Device (including the GPS location and information about WLAN access point, Bluetooth, base stations and other sensors acquired by us under your Authorization), of the Device used by you according to the specific permissions granted by you during the installation and use of the software . In order to collect the above basic personal Device information, we will apply for permissions to access to your Device information and obtain relevant information according to your Authorization, and you may at any time withdraw your Authorization for acquisition of your geographic location information.
We collect such information for the purpose of providing you with our content display/browsing/playing/download services. Your refusal to provide such information and/or permissions may cause the unavailability of our products and services to you. Please note that Device information or log information alone [is] information that cannot identify a specific User.
6. When you use the search function, we will automatically collect certain information about you, including the following Personal Information: words searched for, browsing history and time, and search time. We will collect such information in order to realize the search function only after you actively fill in the relevant information in the search box and click “Search”. We collect such information in order to provide you with the content of your need and services you may be of greater interest, and to improve our products and services.
7. When you purchase any goods or services from our products and/or services, we will collect and use your Payment Method in Consumption Records (which is a function developed by us for access to the third-party software development kit (SDK)), payment account, payment status and other information. Should you refuse our collection of such information, you will not be able to purchase/redeem goods and/or services from our products and/or services, however, this will not affect your use of other products and/or services offered by us.
8. We need to collect some of your information to comprehensively determine the security of your Account and system when you use our products and/or services, and make necessary recordings, audits, analyses and handling according to the determined ID, Account and transaction risks and for the purposes of identity verification, customer service, detection and prevention of security incidents, fraud monitoring, archiving and backup. In case of any actual or threatened Account security risk upon detection, we will use relevant information for security verification and risk elimination, so as to ensure the security of the products and services we provide to you, and protect your rights and interests against infringement. And in case of any Account or system security problem, we will collect this information to optimize our products and services.
9. In order to ensure the security and reliability of our products/services, prevent network security incidents such as computer viruses, network attacks, network intrusions and network vulnerabilities, and protect the personal and property safety of yours, other Users, and AllMyTracks Technology, we need to collect the identity information, common Device information, service log information, etc. from Users, and may use such information of yours alone or in combination with others to comprehensively determine the security of your Account, conduct identity verification, detect and prevent security incidents, conduct data backup, and make necessary recordings, audits, analyses and handling.
10. During your use of our products and/or services, we may provide you with other necessary customer services according to the information you provide, and we may remind or contact you by email, site message or otherwise. For example, in case of any major release or material update, we may notify you by email, site message, system notice or otherwise.
11. During your use of our services, we may collect and save the information generated by you and other information as may be generated, and use the same to filter pornographic, violent, political, abusive, malicious advertising and other inappropriate content, so as to purify the network environment and maintain a healthy Internet environment.
12. We will require you to provide the necessary Personal Information for matching and authentication of your identity and ensure the security of your Account, when you contact us for any purpose. In order to respond to your requests, we will collect and keep the relevant information provided by you, as well as records of your consultation or related handling.
13. In order to ensure the security and stability of the services and implement specific functions, some of our software may access to the Software Development Kit (SDK) developed by a third party (see the List of Third Party SDK attached hereto for details).
14. After obtaining your Consent, we will collect the relevant information from third parties by legal means.
15. Under applicable laws, regulations and national standards, we may collect and use your Personal Information without your Authorized Consent if:
(1) such Personal Information is directly related to national security, national defense security and other national interests;
(2) such Personal Information is directly related to public safety, public health, and other major public interests;
(3) such Personal Information is directly related to criminal investigation, prosecution, trial and judicial enforcement;
(4) such Personal Information is necessary to obtain in order to protect the material legitimate rights and interests of yours or other individuals, and it is difficult to obtain your personal Consent;
(5) such Personal Information is disclosed to the general public by yourself or collected from public available channels (such as legal news reports, government information disclosure, etc.);
(6) such Personal Information is collected from legally publicly disclosed information;
(7) such Personal Information is information necessary to collect for the purpose of maintaining the secure and stable operation of our products and/or services;
(8) such Personal Information is necessary for the execution of relevant agreements or other signed documents with you and the performance thereof; or
(9) other circumstances as required by competent authorities or provided by the laws and regulations occur.
You understand and agree that the services we provide to you are constantly updated and evolving. When one of our products or services fails to collect your information as described above and such information is indeed necessary, we may obtain your Consent through page prompt, website announcement, site message or otherwise.
1. You understand and agree that we may need to share some of your information with certain business partners for the purposes of necessary and reasonable business operations, satisfaction of your requirements, fulfillment of our obligations in the relevant User Agreement or this Privacy Policy, and exercise of our rights or compliance with legal requirements.
2. In order to ensure the security and stability of the services and implement specific functions, some of our software may access to the Software Development Kit (SDK) or other similar applications developed or provided by third-party service providers, in which case, we may delegate such third party to process, or share with such third party, your Personal Information.
3. You acknowledge and agree that the third-party SDK or similar application accessed by us may collect your Personal Information, and in order to use such services provided by such third party, you agree and authorize the relevant third party to directly collect and process your Personal Information, and the specific category, purpose, protection and opt-out mechanism of Personal Information to be collected shall be subject to the privacy policy, privacy statement and other Personal Information protection rules published on such third party's official website. Your use of third-party services (including any information provided by such third parties to you) is subject to such third party's terms of service and relevant Personal Information protection rules, which you must read carefully. This Policy only applies to the Personal Information we collect, but not the services provided by any third party. You acknowledge and agree that we are not responsible for the collection of your Personal Information by any such third party.
4. We will make commercially reasonable efforts to require such third party to take protective measures for your Personal Information and strictly abide by applicable laws, regulations and regulatory requirements, and to carry out necessary security monitoring over such third party. However, you acknowledge and agree that such third-party services are directly operated by relevant third parties, and we assume no responsibility or liability for such third-party services. Should you find that it may be risky to use such third-party services, we recommend that you immediately terminate relevant operation and contact the third party in time to protect your legitimate rights and interests.
5. For details about the access of SDK, please refer to the List of Third-Party SDK attached hereto.
6. We will share necessary Personal Information of yours internally and with our affiliates, in which case our employees and affiliates will also be bound by this Policy. In case of any intended change to the purpose of use and processing of your Personal Information, we will obtain your Authorized Consent again.
7. Unless otherwise agreed herein, we will not sell, transfer or leak any relevant information of yours to any other party other than AllMyTracks Technology and its affiliates.
8. AllMyTracks Technology reserves the right to use, share or provide Personal Information, if it is: (1) required by laws and regulations; (2) for the purpose of maintaining the integrity and legality of [products and services of] AllMyTracks Technology; (3) only possible for us to implement core functions of our products and/or services or provide the services you need, or handle your disputes or controversies with others, by sharing your Personal Information in some cases; (4) in response to your requests or with your explicit Consent; (5) shared with third parties in order to protect the interests, property or safety of yours, our other users or employees, or AllMyTracks Technology, or social public interest, property or security from damage (for instance, due to fraud or credit risk); (6) shared in accordance with relevant agreements (such as online agreement, platform rules, etc.) or legal documents signed between you and us; (7) for compliance with the relevant agreements between you and other third parties; or (8) for the purpose of cooperating with legal investigation and public security efforts, etc.
Transfer refers to the process of transferring control of Personal Information to another company, organization, or individual. As a general rule, we will not share your Personal Information, except:
1．at your request;
2．with your prior explicit Authorized Consent;
3．for merger, acquisition, reorganization, split, bankruptcy, asset transfer or similar transaction entered into by us, in which your Personal Information may be transferred as a part thereof, in which case, we will require the new controller to continue to comply with and perform all provisions of the Privacy Policy (including the purpose of use, usage rules, security safeguards, etc.); otherwise, we will require it to obtain a new explicit Authorized Consent from you;
4．for other circumstances as provided by the laws and regulations.
5．If we enter into any merger, acquisition, asset transfer or other similar transaction in the future, we will inform you of relevant situation, continue to protect or require the new controller to protect the Personal Information of Users in accordance with laws and regulations and standards not lower than those set forth herein.
If any transfer is necessary due to the above reasons, we will inform you of the purpose of transfer and category of information transferred (if it involves your Personal Sensitive Information, we will also inform you of the content of the sensitive information involved) before the transfer, and only transfer the same after obtaining your Authorized Consent, except as otherwise provided by laws and regulations or otherwise agreed herein.
1. During your use of our services, we will provide assistance for you to manage your Personal Information, so that you can access, copy, transfer, correct, supplement, delete or withdraw your relevant Personal Information.
2. You have absolute control over any data or information provided by you to AllMyTracks Technology. You can view the basic information of your Account (such as ID nickname, and other Personal Information you choose to fill in and provide, subject to specific service settings) through specific service software, and correct and supplement the basic information of your ID, where appropriate.
3. Should you need to copy, transfer, delete or withdraw the Authorized Consent, or have any questions during access, correction or supplement, you may contact us through the methods set forth herein. We will deal with your request in a timely manner in accordance with the laws, after verifying your identity. Should you choose to withdraw the Authorized Consent, please note that after the withdrawal of Authorization, we will not be able to continue providing you with the services corresponding to such Authorization, provided, however, that your decision to withdraw the Authorization will not affect the information processing already carried out based on your Authorization and its validity.
4. If a User dies, his or her close relatives can contact us through the methods set forth herein, and we will cooperate with his or her close relatives to exercise their legal rights in accordance with the laws.
Cookies are small pieces of data that we may send to the hard disk of a User's computer in order to record the User. Similar Tracking Technologies are other technologies that can be used for purposes similar to Cookies, such as: Web Beacon, Proxy, embedded scripting, etc. With the help of Cookies and Similar Tracking Technologies, websites can remember certain information about Users, making it easier for Users to browse the web. For example, in order to track the total number of visitors to our website on an anonymous aggregate basis, we may also employ Cookies and Similar Tracking Technologies so that we remember number of your visits to the website, to keep track of the items and sections you follow, or to administer your experience of participating in various activities on the website. In such cases, AllMyTracks Technology may use your Personal Information in combination with Cookies and Similar Tracking Technologies.
Users may log in to use the services offered by AllMyTracks Technology through a third-party Account, which is not controlled by AllMyTracks Technology, and AllMyTracks Technology will not be responsible for the content of any third-party Account and any changes or updates thereto. When you use an Account of such third parties to log in or use the services, we will obtain relevant information under such Account (including: nickname, ID, friend relationship or other information subject to your Authorization) according to your Authorization, so as to help you complete Account linking, login or for better use of our services. We only provide you with ways to log in to use our services through third-party Accounts for convenience purposes only, but our provision of such ways shall not mean our recognition of such third-party Accounts. You are responsible for checking and complying with the relevant regulations of such third-party Accounts.
We may provide links to websites other than AllMyTracks Technology in the services provided by AllMyTracks Technology. When you enter other websites through such links, please read the relevant terms on User privacy protection of such websites, and AllMyTracks Technology will not be responsible for the privacy protection rules of other websites.
AllMyTracks Technology attaches great importance to the information security of Users. We make efforts to take all reasonable physical, electronic, and managerial security measures to protect Personal Information from unauthorized access, public disclosure, use, modification, damage or loss. We will: (i) use encryption technologies to ensure security of Personal Information; (ii) use trusted protection mechanisms to prevent malicious attacks on Personal Information; (iii) deploy access control mechanisms to endeavor to ensure that only authorized personnel have access to Personal Information; and (iv) conduct security and privacy training courses to enhance staff awareness of the importance of protecting Personal Information.
In any unfortunate event of any security incident such as Personal Information breach, AllMyTracks Technology will initiate an emergency response plan to prevent the enlargement of the security incident, and inform you of the basic situation of the security incident, the handling measures and remedial measures to be taken or already taken, and the response suggestions, in the form of push notification, announcement or otherwise.
Please understand that due to the limitations of current technologies and risk prevention measures, while we have made reasonable commercial efforts to strengthen information security protection measures, we cannot guarantee its absolute security. And the Internet is not an absolutely secure environment, we strongly recommend that you take active measures to ensure the security of Personal Information, such as: please use sophisticated passwords, regularly change Account passwords, and do not leak Personal Information such as ID and passwords to others.
AllMyTracks Technology will only store the collected User-related information in a secure way for the period necessary to achieve the purpose of the service and for the period stipulated by laws and regulations.
You acknowledge and agree that AllMyTracks Technology may extend the storage period of Personal Information if, among others, (1) it is required by laws and regulations or administrative authorities; (2) it is reasonably necessary to protect the legitimate rights and interests of AllMyTracks Technology or its affiliates or other Users and customers; or (3) it is for the purpose of cooperating with legal investigation, public security efforts, and complying with court decisions or rulings, etc.
If we terminate the services or operation, we will promptly stop any activity that will continue collecting Personal Information, and comply with applicable laws and regulations to notify you in advance, and delete or anonymize your Personal Information after terminating the services or operation, unless otherwise required by laws, regulations or regulatory authorities. When you apply for cancellation or deletion of Personal Information, or after your Personal Information is stored for the necessary retention period, we will delete or anonymize your Personal Information unless the laws and regulations require otherwise. You acknowledge and agree that the Personal Information cannot be restored once deleted or anonymized.
We value the protection of Personal Information of minors. If you are a minor , it is recommended that your legal guardians carefully read this Statement, and you need to use the corresponding services of or provide information to AllMyTracks Technology only after obtaining the Consent of your guardians. AllMyTracks Technology will only collect, use or disclose the Personal Information of minors as permitted by laws and regulations, with the express Consent of their guardians or to the extent necessary to protect minors.
AllMyTracks Technology will strictly perform the legal obligations and responsibilities for the protection of minors, and we will only collect, use, share, transfer or disclose Personal Information of minors as permitted by law, with the Consent of guardians, or to the extent necessary to protect the minors. If we find that any minor has used our products and/or services without the prior Consent of their guardians, we will do our best to contact the guardian and delete the Personal Information of such minor as soon as possible at the request of the guardian.
This Privacy Policy is an integral part of the AllMyTracks User Agreement. AllMyTracks Technology may adjust or change this Privacy Policy from time to time, where necessary. Any update to this Privacy Policy made by us will be posted on our website by indicating the update time, and unless otherwise mandatorily required by laws, regulations or regulatory provisions, the adjusted or changed content will take effect after notification or publication. We recommend you regularly check the latest terms of this Policy online. No future update to the terms hereof will be notified to you by further notice from us, or have retrospective effect on your previous operations on the website in the past, or change the way in which we process the information already collected.
By continuous use of any of our services or visit to our relevant websites after the Privacy Policy is adjusted or changed, you are deemed to have fully read, understood, and accepted to be bound by the revised Privacy Policy.
Should you have any questions about this Policy, or any related complaints, comments or requests, please contact us as follow email: [customer-service@allmytracks.com]. After we receive your questions or comments, we will review them as soon as possible, and deal with them in a timely manner after verifying your identity, and reply within a maximum of fifteen days or the period provided by laws and regulations.
AllMyTracks Technology