Shanghai SUNMI Technology Co., Ltd. (registered office: Room 505, No. 388, Songhu Road, Yangpu
District, Shanghai, Tel.: 400-6666-509, hereinafter referred to as “SUNMI” or “we”) is a
provider of a series of SUNMI devices. We attach great importance to the protection of personal
information and privacy of our users (“You”). When you register and use SUNMI devices and related
products or services (“Services”), we will collect, use, store and share your personal information.
In order to make you informed of our processing of your personal information, we have prepared the SUNMI
Device Privacy Policy (“Privacy Policy”) and promise to process your personal information in strict
accordance herewith.
We hereby remind you of the following matters:
Before using SUNMI devices, please be sure to carefully read this Privacy Policy and fully
understand the terms and conditions, including but not limited to the terms and conditions that exempt
or limit our liabilities. You know and confirm that when you check “Agree” to this Privacy Policy and
use or continue to use SUNMI devices, it will be deemed that you have fully read,
understood, and accepted the updated Privacy Policy.
SUNMI device may contain links to other third-party websites or applications. Please note that we
do not control such third parties, and this Privacy Policy does not apply to services provided by other
third parties to you under any circumstances. We suggest that you carefully read the personal
information protection policies or statements of third parties before browsing or using their websites
or applications, and make appropriate choices. If you find any risks in these websites or applications
created by third parties, you are advised to terminate relevant operations to protect your legitimate
rights and interests. We do not participate in and will not assume any responsibility for any dispute
between you and any third party arising from personal information protection and other
matters.
This Privacy Policy will tell you:
I. Personal information We Process &
How We Use Your information
II. How We Retain Your Personal
Information
III. How We Entrust Others for Processing, Share, Transfer and Publicly
Disclose Your Personal Information
IV. How We Protect Your Personal Information
V. How to Manage Your Personal Information
VI. How We Process the Personal Information of Minors
VII. How the Privacy Policy is Updated
VIII. How to Contact Us
I. Personal information We Process & How We Use Your
information
When you use our products/services, we need/may need to collect and use your personal information
as follows:
1. The necessary information that you shall authorize us to
collect and use to provide the basic functions of our products and/or services. If you refuse to provide
the relevant information, you will not be able to use our products and/or services normally;
2. The information that you may choose to individually agree or
disagree to be collected and used by us in order to provide the additional functions of our products
and/or services. If you refuse to provide such information, you will not be able to normally use the
relevant additional functions or achieve the functional effect we plan to achieve, and your use of the
basic functions of our products and/or services will not be affected.
We will explain in detail the type and purpose of processing your personal information. In
addition, for users resident in the European Economic Area ("EEA"), the United Kingdom, or Switzerland,
it also identifies the legal basis under which we process your data.
(I)Basic Business Functions
1. StoreCenter Function
(1) Log on to Register
For details about how we process your personal information during your registration and login, you
may read the SUNMI Account Privacy Policy.
You may also add your E-mail to your account, add nickname information, enable the camera and photo
album permissions of your device, and take and upload your account profile picture to complete your
account information and facilitate us to provide you with a better service experience. If you reject to
provide such information, the security protection and the personalized setting of your account will be
affected, provided that the account registration function will not be affected.
You can also not add the SUNMI account to your SUNMI device, and we do not need to collect the above
personal information, which will not affect your normal use of your SUNMI device.
For users in the EEA, the United Kingdom, or Switzerland, you may register or log in to your
account with an E-mail only and cannot change your account profile picture or nickname. The legal basis
for us to process your personal information is necessary to perform our contract with you to provide you
with the services related to SUNMI Devices.
(2)Complete Store Information
If you plan to complete your store information, we need to collect information such as contact
person, telephone number, store icon, address, store name, business category, business hours, store area,
duration of operation, and fixed expenses such as monthly rent of the store, and monthly average expenses
for water, electricity and coal that you have filled in or uploaded. At the same time, you can authorize
us to enable the location permission of your device, so that we can automatically collect the
address information of the store through the system tools, instead of you filling in the address
information manually. The above information is collected to help you complete your store information. If
you do not provide the above information, the normal use of other services provided by us will not be
affected. In addition, it should be noted that you shall obtain the consent of the contact person
before completing the contact information.
For users in the EEA, the United Kingdom, or Switzerland, we will only collect the E-mail address
that you have filled in and please do not upload your mobile phone number. The legal basis for us to
process your personal information is necessary to perform our contract with you to provide you with the
services related to SUNMI Devices.
(3)Add Clerk Information
If you plan to add clerk information to your store, we need to collect the clerk’s profile photo,
nickname, mobile phone number, E-mail address, joining time and login time you have filled in. We collect
the above information to help you complete the clerk information and manage the store. If you do not
provide the above information, this will not affect your normal use of our other services. In
addition, it should be noted that you shall obtain the consent of the clerk before completing the
clerk’s information.
For users in the EEA, the United Kingdom, or Switzerland, we will only collect the clerk’s E-mail
address and please do not fill in the clerk’s mobile phone number. The legal basis for us to process
your and the clerk’s personal information is necessary to perform our contract with you to provide you
with the services related to SUNMI Devices.
(4)Data Backup
When you use the data backup function, we need to collect your location information, battery
information, clock information, Bluetooth information, sound, application information, display
information, accessibility setting information and safety information. We collect the above information to
provide you with a data backup service. If you do not provide the above information, you will not be able
to realize the data backup function, but it will not affect your normal use of our other services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you
with the services related to SUNMI Devices.
(5)Add the Device
In order to add your device to your StoreCenter, we will collect your device SN. We collect the
device SN to assist you in adding your device to your store so that you can better understand the
operation of your store. If you do not provide the above information, it will not affect your normal use
of our other services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
2. Using a SIM Card
If your device requires a data connection, you can connect your device with a SIM card. In such case,
we may need to collect your SIM card information and data only SIM card number to steadily provide you
with services. You can choose not to connect your SUNMI device with a SIM card. If you choose to use an
ESIM card or connect to a WLAN, we do not need to collect your foregoing personal information, and this
will not affect your normal use of your SUNMI device.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you
with the services related to SUNMI Devices.
3. ESIM Function
In order to provide you with ESIM functions, we need to collect your device number and
ESIM card number, and software version information; at the same time, we need to enable the
automatic start permission of the applications on your device. We collect the above
information from you to provide you with the ESIM function, which allows you to connect to
the cellular network through the ESIM and maintain daily operation. If you do not provide the above
information, we will not be able to provide the ESIM networking function for you, but it does not affect
your normal use of our other services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you
with the services related to SUNMI Devices.
4. Printing Function
When you use the printing service, we will, with the system tools, automatically collect
your operation behavior, device information (including device model, IP address, device software
version information, device identification code, and device identifier), cash drawer use times,
overheating times, printing times, and printing paper distance. We collect the above information to help
you complete the printing function. If you do not provide the above information, we will not be able to
assist you in completing the printing function, but it will not affect your normal use of our other
services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
5. Online Upgrade Service
When you use the online upgrade device service, we will, with the system tools,
automatically collect your device information (including device model, device software version
information, and device identification code). We collect the above information to help you complete the
online upgrade service. If you do not provide the above information, we will not be able to assist you in
completing the online upgrade, but it will not affect your normal use of our other services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
6. Log Analysis Tools
To provide you with log analysis tools, we will, with the system tools, automatically
collect information of the remaining space on your device’s hard disk. We collect the above information to
help you manage your device. If you do not provide the above information, we will not be able to provide
you with log analysis services, but it will not affect your normal use of our other services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
7. Interface Open Service
When you call the interface of the interface open service (log service), we will with
the system tools, automatically collect your device SN, model, call interface APK package name and call
time. We use the above information to help you solve the problem when there is a problem with the
interface call. If you do not provide the above information, we will not be able to provide you with
interface problem analysis services, but it will not affect your normal use of our other services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
8. Push Service
When you use the push service, we will, with the system tools, automatically collect
your device information (including device number, model, system firmware version number), ROM version,
longitude and latitude, current connection network type, and the times of connection configuration
requests.We collect the above information for statistical usage details of the service, for analysis and
iterative upgrade of the service. If you do not provide the above information, we will not be able to
accurately analyze the information, but it will not affect your normal use of the business.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
9. OCR Function
When you use the OCR function, SUNMI Devices will collect the pictures or other forms of files
that you have uploaded for identification, and the recognition of the relevant images or files will be
only completed locally on the device. We collect the above information to assist you in identifying
the aforementioned contents into texts. If you do not provide the above information, we will not be
able to provide you with OCR Function, but it will not affect your normal use of our other
services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
10. Barcode Reader Function
When you use the barcode reader function, SUNMI device will collect images or other files that you
actively upload for identification purposes, and process these files locally on the device only.
Specifically, if you encounter a failed scan, we may collect the images of the barcodes that could not be
recognized. We collect the aforementioned images to obtain the causes of scan failures, and in certain
cases, use some images as training data to optimize the barcode recognition algorithm, thereby assisting
you in better utilizing the barcode recognition feature. We will anonymize the personal information within
the images and employ segmentation filtering techniques to minimize the collection of sensitive data. If
you do not provide the above information, we will not be able to assist you in accurately recognizing
scanned content and optimizing the scanning algorithm, but it will not affect your normal use of our other
services.
11. Use Wallpaper Service
When you use the wallpaper service, we will, with the system tools, automatically
collect your selected wallpaper pictures and your wallpaper click actions. We collect the above
information to assist you in using and replacing wallpapers. If you do not provide the above information,
we will not be able to provide you with wallpaper use services, but it will not affect your normal use of
our other services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
12. App Store Function
When you use the App Store function, we will, with the system tools, automatically the
number of application installation updates, installation status information, application evaluation and
user name. We collect the above information to assist you in using the App Store function. If you do not
provide the above information, we will not be able to assist you in completing the installation and
download of the application, but it will not affect your normal use of our other services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
13. Geo-Fencing Function
To provide you with the geo-fencing function, we need to enable the location
permission of your device, and with the system tools, automatically
collect latitude and longitude information. We collect the above information to provide you with an
anti-theft reminder service. Once the device is taken from the fixed area, we can warn you in time. If you
do not provide the above information, we will not be able to provide you with the geo-fencing function,
but it will not affect your normal use of our other services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
14. SUNMI Pay
To provide you with the SUNMI Pay function, we will enable the location and camera
permissions and network permissions of your device, and with the system
tools, automatically collect the device number and model information, latitude and
longitude information, software version information,
and transaction amount information.We collect the above information to provide you
with the collection function and update the SUNMI Pay system, which enables you to collect money normally
and maintain your daily operation. If you do not provide the above information, we will not be able to
provide you with the collection function, but it will not affect your normal use of our other
services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
15. Hardware Manager
To provide you with the hardware manager function, we will enable the camera,
recording and MIC permissions of your device, and with the system tools,
automatically collect the device inspection information (including screen, battery, code scanning, MIC,
network, NFC, and device detection information of the printer. Inspection results vary from devices), and
device parameter information (including device model, device SN, hardware manager version, and screen
size). We collect the above information to provide you with the hardware manager function, which enables
you to normally carry out device testing through the hardware manager. If you do not provide the above
information, we will not be able to provide you with the device testing function, but it will not affect
your normal use of our other services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
16. Kiosk Function
To provide you with the kiosk function, we will, with the system tools, automatically collect your
device SN, firmware version, device model and application package name. If you do not provide the above
information, we will not be able to provide you with the kiosk function, but it will not affect your
normal use of our other services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
17. App Locker Function
To provide you with the App locker function, we will, with the system tools, automatically collect
your device SN, firmware version, device model and application package name. If you do not provide the
above information, we will not be able to provide you with the App locker function, but it will not affect
your normal use of our other services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
18. Fingerprint Recognition
Before using the fingerprint recognition function provided on some SUNMI devices, you need to
proactively register your fingerprint through the SUNMI devices. We will only store the unique
fingerprint characteristics generated based on your fingerprint image locally on your device. The
aforementioned fingerprint characteristics will only be stored in the Trusted Execution Environment
(TEE) of your SUNMI devices, and processes such as fingerprint recognition and comparison will be
completed locally on your SUNMI devices.
19. Customer Services and User Feedback
When you send us complaints, suggestions, or feedback through our feedback system, we may collect
your correspondence or call records with us, the account and contact
information you provide, and the information you provide to prove the related facts. We collect the above
information for the purpose of contacting you, helping you solve the issues as soon as possible or
recording the solutions and results of the relevant issues. If you do not provide the above information,
your complaints, suggestions, and feedback may not be timely and effectively handled, provided that, the
normal use of our services will not be affected.
Please do not disclose your other information, especially your personal privacy information, to
us, in addition to the aforementioned necessary personal information when making complaints,
suggestions, or feedback.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is necessary to realize your legitimate interests (that is, to help you get in
touch with us so that you can make complaints, suggestions, and feedback) and to perform our contract
with you to provide you with the services related to SUNMI Devices.
20. Improving and Ensuring the Safety and Stability
of Services
To improve and ensure the safety and stability of the services, we need to automatically collect your
network logs and device logs with the system tools. We collect the above information to assist you in
dealing with the relevant problems, and improve or enhance our service quality. If you do not provide the
above information, this will not affect your normal use of our other services.
For users in the EEA, the United Kingdom, or Switzerland, the legal basis for us to process your
personal information is to ensure the security of our services, which is in line with our legitimate
rights and interests and is necessary to perform our contract with you to provide you with the services
related to SUNMI Devices.
(II)Add-on Business Functions
1. Invoking device permissions
During your use of the SUNMI device, we may invoke your device permissions. Please refer to the
following table for the SUNMI device permissions invoked, the purpose of the permissions invoked:
Device permissions
|
Purpose of invoking the permissions
|
Location permission
|
Assist you in using the geo-fencing function
Assist you in filling in the address information when you use the
StoreCenter
Make sure your cashier is safe when you use the SUNMI Pay
Assist you in using the location collection function of
DataService
|
Camera permission
|
To facilitate you upload your profile photo in the
StoreCenter
To assist you in completing facial recognition payment at the
SUNMI Pay
To assist you in implementing the hardware manager detection
function
|
Photo album permission
|
To facilitate you upload your profile photo in the
StoreCenter
|
MIC permission
|
To assist you in implementing the hardware manager
detection function
|
Network permission
|
To ensure the normal transaction of the SUNMI Pay
To ensure the normal calling of connecting ability
To assist you in realizing the automatic update of the SUNMI
Pay
To assist you in using the MDM management function
To assist you in using the remote assistance function
To assist you in using the remote system upgrade function
To materialize the APK distribution function for App Store
To assist you in using the uploading function of
DataService
|
Storage permission (reading and writing SD card permission)
|
To assist you in realizing the gallery function
To assist you in realizing the music-playing function
To assist you in realizing the downloading function
To assist you in realizing the log storage function
To assist you in realizing the OTA local upgrade function
To assist you in using the information storage function of the
DataService
|
Log permission
|
To assist you in reading the Tools Log
|
Recording permission
|
To assist you in implementing the hardware manager detection
function
To assist you in using the remote call assistance function
|
Voice call permission
|
To assist you in using the remote call assistance function
|
Application self-start permission
|
To assist you in realizing the ESIM networking function, so that
the application can be automatically started upon startup
To assist you in using the MDM management function
To start the APK necessary to be updated for self-downloading for
App Store
To assist you in automatically detecting system update function
after startup
To assist you in automatically starting the DataService after
startup
|
Telephone permission
|
To assist you in conducting equipment management and mobile data
network identification and realizing the upgrade function
|
Installation package permission
|
To assist you in using the MDM management function
|
Notification permission
|
Making a notification with a message to assist you in upgrading
the system in time
|
Device manager permission
|
To assist you in using the MDM management function
|
Vibrate permission
|
To assist you in realizing the Tstylus prompt function
|
Bluetooth permission
|
To guarantee to add your device to ThingService normally
To facilitate the backup of StoreCenter and recover the Bluetooth
on-off
To assist you in using the Bluetooth information collection
function of the DataService
|
Audio setting permission
|
To assist you in using the MDM management function
|
Package visibility permission
|
To ensure the normal calling of SUNMI Pay
To ensure normal calling of all available services under
ThingService
To assist you in realizing the SUNMI Link Wi-Fi connecting function conveniently
|
Resident notification permission
|
To ensure the stability of the remote download process of the
system, and check the download progress in real time
|
Screenshot permission
|
To assist you in using the remote assistance function
|
Remote desktop permission
|
To assist you in using the remote assistance function
|
Permission to read device status and identifier
|
To facilitate the device to obtain the device model and
identifier
|
Accessibility permission
|
To assist you in using the remote assistance function
|
Alarm clock permission
|
To facilitate the device to perform timing tasks
To assist you in upgrading in time and remind you
regularly
|
To access system installation package information
|
To facilitate the APP Store to check whether the Apps in the
system are updated
|
Backup permission
|
To realize the backup function of the StoreCenter
|
Permissions related to the device account
|
To assist the StoreCenter in managing the device account
|
If you wish to disable the permissions, you can choose to disable some or all of your permissions in
the device's settings function, thereby denying us to collect your related personal information.
2. Use of cookies and similar technical services
(1) In order to ensure the proper operation of the website or your better visit experience, we may store
small data files called cookies on your computer. Cookies usually consist of identifiers, site names,
numbers, and characters. Cookies allow us to collect your preferences and related data.
(2) We will not use the cookies for any purpose other than those described
herein. You may enable or disable the cookies by following the relevant instructions in your browser
settings, provided that your browser or browser add-on service allows it. For more details, please visit
https://www.aboutcookies.org/. However, if the cookies are disabled, some functions of our website may not
work properly.
(III)How We Use Your Personal Information
1. We will only collect and use your personal information in accordance
with the purpose and scope specified herein. When we use your personal information for other purposes not
specified herein, we will seek your consent in advance or have other legal reasons.
2. The sensitive personal information collected by us has been
displayed in this Privacy Policy through prominent flags. Once your sensitive personal information is
leaked, altered or illegally used, it will damage your personal or property safety. In order to prevent
your sensitive personal information from being leaked or illegally used, we have taken appropriate
technical and organizational protection measures to ensure the security of your information.
3. If the information you provide contains the personal
information of other users, you need to ensure that you have been legally authorized before providing
such personal information to us. If the personal information of a child is involved, you shall obtain
the consent from guardian of the corresponding child before posting it. Under the above circumstances,
the guardian has the right to contact us through the channels specified herein to request correcting or
deleting the content involving the child's personal information.
4. Please note that the personal information you provide when
using our services will continue to be authorized to be used by us during your use of our services
unless you delete it or refuse us to collect it through system Settings.
5. We will collect statistics on the use of our services and may provide
such statistics to the public or third parties for product development, service optimization, and security
assurance. However, such statistics do not contain any identifying information about you.
6. We will desensitize your personal information before display
according to the actual business functions, including masking, shielding, and other de-identification
technologies, to protect your information security.
(IV)Other Circumstances in Which Personal Information is Collected or
Used
In accordance with relevant laws and regulations, we may collect and use your personal information
without your prior consent under the following circumstances:
(1) Necessary for the conclusion and performance of the contract
to which you are a party;
(2) Necessary for fulfilling legal obligations;
(3) Necessary for dealing with public health emergencies or
protecting the life, health, and property safety of natural persons in emergencies;
(4) Collecting personal information within a reasonable range
through news report and public opinion supervision for public interests;
(5) Collecting the personal information that has been disclosed
by yourself or other personal information that has been legally disclosed within a reasonable scope in
accordance with the provisions of this Policy;
(6) Other circumstances as provided for by laws and
administrative regulations.
II. How We Retain Your Personal Information
(I)Storage Location
Currently, SUNMI has data centers in China, Germany, and the United States. For the purposes described
in this privacy policy, your personal information may be transferred to these data centers in accordance
with applicable laws:
1. Personal information collected and generated within China will be stored in China.
2. For users registered through the European Union site operated by SUNMI (domain: *.eu.sunmi.com),
your personal information will be stored on Amazon servers located in Germany.
3. For users registered through the North American site operated by SUNMI (domain: *.us.sunmi.com),
your personal information will be stored on Amazon servers located in the United States.
4. For users outside of China who do not register through the EU or North American sites, your personal
information will be stored in China.
(II)Retention period
1. We will retain your personal information within the minimum retention
period necessary for the purposes stated herein and required by laws and regulations. Upon the expiration
of the foregoing period, we will delete or anonymize your personal information. Unless otherwise
stipulated by law, please refer to the following table for the retention period of your relevant personal
information:
Number
|
Data type
|
Retention period
|
1
|
Registration and login data, and account information data
|
Your registration and login data will not be deleted or anonymized until your account is
canceled
|
2
|
Real-name authentication
|
Your registration and login data will not be deleted or anonymized until your account is
canceled
|
3
|
Store information and clerk information
|
Such information will be deleted or anonymized when you cancel your account or delete
relevant data on your initiative
|
4
|
Network operation security data
|
Your network operation security data will be retained as provided for by the law (for
example, it shall be retained for 6 months in China).
|
2. If we terminate the services or operation, we will notify you at least
30 days in advance, and delete or anonymize your personal information upon termination of the services or
operation.
(III)How Personal Information is Transferred Around the World
There are SUNMI’s clients all over the world, which means that SUNMI may process personal information
in your countries or regions, or be accessed from these countries/regions. Data
protection laws may vary in these countries/regions. In such cases, SUNMI will take steps to ensure that
the data we collect is processed in accordance with the requirements of this statement and applicable
laws.
III. How We Entrust Others for Processing, Share, Transfer and Publicly
Disclose Your Personal Information
(I) Entrust Others for Processing
We may entrust authorized affiliates or partners to process your personal information in order to
provide you with corresponding products or services. However, provided that, we will only entrust
authorized partners to process your personal information for legal, legitimate, necessary, specific, and
explicit purposes, and will only provide personal information necessary for using our products or
services. Our partners will not use your personal information for purposes not entrusted by us before
your consent.
If we entrust our partners to process your personal information, we will sign a Data Protection
Agreement with them, requiring them to process your personal information in accordance with the Agreement,
this Privacy Policy, and relevant laws and regulations.
(II)Sharing
We will not share your personal information to external parties. If it is indeed necessary to share your
personal information to external parties, we will obtain your separate consent or meet other conditions as
provided for by laws.
(III) Transfer
If any merger, division, dissolution, or bankruptcy involves the transfer of personal information, we
will require the company or organization receiving your personal information to continue to be bound by
this Policy, or we will require the company or organization to obtain your new authorization.
(IV) Public Disclosure
In principle, we will not publicly disclose your personal information. If it is indeed
necessary to publicly disclose your personal information, we will obtain your separate consent or meet
other conditions as provided for by laws.
(V) How Third-Party Service Providers Obtain Your Personal Information
For the purpose of providing you with richer and more complete functions, we may use
the third-party service providers described below, including third-party software development
kits (SDKs) to provide you with our services. We will carry out strict security inspection on the
application programming interface (API) and software development kits (SDKs) of third-party
service providers to obtain relevant information, and agree with third-party service
providers on strict data protection measures, so that they may process your personal information in
accordance with this Privacy Policy and any other relevant confidentiality and security measures. The
specific information collection and use of the third-Party services is governed by the
third-Party service providers' privacy policies or relevant statements.
If you are a user in China, the third-party services we access are as follows:
Number
|
Name
|
Access Purpose
|
Subordinate to
|
Type of Collected Information
|
Service Agreement/Privacy Policy Link
|
1
|
Tencent Bugly
|
Statistical analysis services of the App Store and the StoreCenter
|
Shenzhen Tencent Computer Systems Company Limited
|
Click, access page, access length, ROM version, component version, network status, user
device number, and SD card information
|
Bugly SDK Personal Information Rules:
https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56
|
2
|
Baidu Statistics
|
Page statistics service
|
Beijing Baidu Netcom Science Technology Co., Ltd.
|
Number of views, clicks, web pages visited, access time, number of visitors, number of IP
addresses, geographical distribution, browser, network device type, screen resolution, screen
color, flash version, language environment, and network provider
|
Baidu Promotion Service Agreement
http://e.baidu.com/accept.html/
Baidu Statistics Privacy Policy
https://tongji.baidu.com/web/help/article?id=330&type=0/
|
3
|
Umeng Analytics
|
Statistical analysis services
|
Umeng Tongxin (Beijing) Technology Co., Ltd. and Beijing Ruixun Lingtong Technology Co.,
Ltd.
|
Device Mac address, unique device identification IMEI/android ID, IDFA, OPENUDID/GUID, SIM
card IMSI information, geographical location, device model, software version, login phone
number, page operation data, and information on enabling the permissions to read phone status
and SD card.
|
Umeng Privacy Policy:
https://www.umeng.com/page/policy?spm=a213m0.13887608.0.0.3cb275efA3prdz
|
4
|
Alipay face verification SDK
|
Facial recognition payment of the SUNMI Pay
|
Alipay (China) Network Technology Co., Ltd.
|
Face information, mobile phone number, and Alipay account
|
Alipay Privacy Policyhttps://render.alIPay.com/p/c/k2cx0tg8
Personal Information Processing Rules for Face Verification SDK
https://opendocs.alipay.com/common/067k4b
|
5
|
Amap SDK
|
Help users locate stores and your devices
|
AutoNavi Holdings Limited
|
Device identifier (In case of an Android device, it includes Android ID, IMEI, MEID, IMSI,
OAID, and Serial. In case of an iOS device, it includes IDFV and IDFA), MAC address, IP address,
location information (such as GPS, WLAN access point, Bluetooth and base station), device
sensor, and current application information (application name and application version
number).
|
https://lbs.amap.com/pages/privacy/
|
6
|
Mi PUSH SDK
|
Push notifications
|
Beijing Xiaomi Mobile Software Co., Ltd.
|
Device identifier (such as IMEI, Android ID, MEID, Serial, OAID, and GAID), and location
information (WLAN access point)
|
https://dev.mi.com/console/doc/detail?pId=1822
|
If you are a user outside China, the third-party services we access are as follows:
Number
|
Name
|
Access Purpose
|
Subordinate to
|
Type of Collected Information
|
Service Agreement/Privacy Policy Link
|
1
|
Alipay face verification SDK
|
Facial recognition payment of the SUNMI Pay
|
Alipay (China) Network Technology Co., Ltd.
|
Face information, mobile phone number, and Alipay account
|
Alipay Privacy Policyhttps://render.alIPay.com/p/c/k2cx0tg8
Personal Information Processing Rules for Face Verification SDK
https://opendocs.alipay.com/common/067k4b
|
2
|
Amap SDK
|
Help users locate stores and your devices
|
AutoNavi Holdings Limited
|
Device identifier (In case of an Android device, it includes Android ID, IMEI, MEID, IMSI,
OAID, and Serial. In case of an iOS device, it includes IDFV and IDFA), MAC address, IP address,
location information (such as GPS, WLAN access point, Bluetooth and base station), device
sensor, and current application information (application name and application version
number).
|
https://lbs.amap.com/pages/privacy/
|
3
|
Mi PUSH SDK
|
Push notifications
|
Beijing Xiaomi Mobile Software Co., Ltd.
|
Device identifier (such as IMEI, Android ID, MEID, Serial, OAID, and GAID), and location
information (WLAN access point)
|
https://dev.mi.com/console/doc/detail?pId=1822
|
IV. How We Protect Your Personal Information
(I)Data Security Management and Technical Measures
We have taken security measures that meet industry standards to protect your personal information and
prevent unauthorized access, public disclosure, use, modification, damage, or loss of your data. We will
continue to make every effort to take all reasonably practicable measures to protect your personal
information. For example, the data exchange between your browser and the server is protected by the Secure
Socket Layer (SSL) protocol encryption; We use encryption to improve the security of your personal
information; We use trusted protection mechanisms to prevent malicious attacks on your personal information;
We deploy access control mechanisms to ensure that only authorized personnel have access to your personal
information; And we organize security and privacy training courses to enhance employees’ awareness of the
importance of protecting your personal information. At present, our important information system has been
filed and evaluated in network security level protection.
(II)Responding to Data Security Incidents
After an unfortunate occurrence of any personal information security incident, we will inform you, in
accordance with the requirements of laws and regulations, of the basic situation of the security incident
and the possible impacts, the disposal measures we have taken or will take, the advice on your own risk
prevention and mitigation, the remedial measures for you, etc. We will inform you about the incident by
email, letter, telephone, push notification, and other means. If it is difficult to inform you one by one,
we will make announcements in a reasonable and effective way. In addition, we will also actively report
the disposal of the personal information security incident in accordance with the requirements of the
regulatory authorities.
V. How to Manage Your Personal Information
During your use of our services, you may contact us through the prompts on the corresponding page or the
mode as set forth herein to access, port, object or limit the processing of, rectify, supplement or erase
your personal information, and exercise the right to change the scope of your consent and cancel the
account. In addition, we have set up complaint-reporting channels, and your opinions will be dealt with in
time.
1. Right of access
If you want to access your information, such as the store and clerk information and the password, you
may, in the StoreCenter interface, follow the relevant instructions, or contact
us through the contact information provided herein.
2. Right to data portability
If you need to transfer your personal information in part or in full to your designated personal
information processor, you may contact us through the contact information provided herein. We will review
your request, and provide you with a transfer route within 15 days or within the time limit stipulated by
law, provided that it meets the requirements of applicable legal.
3. Right to object to automated decision making
We do not involve the use of automated decision-making in the products and services we provide to you.
4. Change the scope of your consent
You may contact us in the manner set forth herein to change the scope of your consent or cancel your
authorization. Please understand that such function of the SUNMI device may be
materialized only after partial permissions are enabled and necessary personal information is collected.
When you withdraw your consent, we will no longer be able to provide you with the
services corresponding to the consent withdrawn, provided that it will not affect the personal
information processing services previously carried out based on your authorization.
5. Account cancellation
If you want to cancel your account, you may do so by contacting us in the manner set forth herein. We
will respond to your request in a timely manner. The cancellation of your account will be irreversible,
and we will stop providing you with services, stop collecting your personal information, and erase or
anonymize the personal information associated with your account upon your
request.
6. Right to rectification
If you want to rectify your information, such as the store and clerk information and the password,
you may, in the StoreCenter interface, follow the relevant instructions, or
contact us through the contact information provided herein, and we will respond to your request for
rectification within 15 days.
7. Right to erasure
You may request us to delete your personal information if:
(1) The processing purpose stated herein has been achieved,
cannot be achieved, or is no longer necessary to be achieved;
(2) You withdraw your consent on which processing your
personal information is based;
(3) The storage term of personal information has
expired;
(4) We collect, use, store, share, or publicly disclose your
personal information in violation of laws and administrative regulations or the agreement with you;
(5) You are no longer using our services;
(6) We stop providing products or services;
(7) Other circumstances as stipulated by laws and
regulations.
We will, upon receipt of your deletion request and verification of your identity, handle
the request and give a reply as soon as possible. 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
such information in time, unless otherwise stipulated by laws and regulations or these entities have
obtained your independent authorization.
When you delete information from our services, we may not immediately delete the
corresponding information from the backup system, provided that we will delete the information when
updating the backup. We will not deal with the personal information whose storage term prescribed by
laws and administrative regulations has not expired, or that is difficult to delete technically, except
by storing and taking necessary security protection measures.
8. Other rights to personal information
Under the condition of complying with relevant laws and regulations, your next of kin may exercise
the above-mentioned right of access, right to rectification, right to erasure, and other rights to your
relevant personal information, unless otherwise arranged by you.
9. Right to explanation
If you have any questions about this Privacy Policy, you may contact us through the contact
information provided herein.
10. Response to your above request
For security purposes, you may be required to provide a written request or otherwise prove your
identity. We may ask you to verify your identity before processing your request. We will respond to your
request within 15 days or within the time limit as provided for by laws.
In principle, no fee will be charged for reasonable requests. However, for requests that are repeated
for several times and exceed reasonable limits, we will charge a fee as appropriate. We may reject
requests that are repeated for no reason, require excessive technology, put the legal rights of others at
risk, or are highly impractical.
11. Response exceptions
We will not be able to respond to your request if:
(1) It is related to the fulfillment of our obligations under the laws
and regulations;
(2) It is directly related to national security and national defense
security;
(3) It is directly related to public safety, public health, and major
public interests;
(4) It is directly related to criminal investigation, prosecution, trial
and sentence enforcement;
(5) We have sufficient evidence of subjective malice or abuse of rights
by the owner of the personal information;
(6) It is related to protection of lives, properties, and other
significant legitimate rights and interests, but it is difficult to obtain the consent of the personal
information owners;
(7) A response to the request of the personal information owner will
result in serious damage to the legitimate rights and interests of the owner or other individuals or
organizations;
(8) It involves trade secrets.
12. Application of special jurisdictions
Please note that if you are a user in the EEA, the United Kingdom, or Switzerland, in addition to
the rights listed above, you also have the right to object. If we use your information for our
legitimate interests or use your personal information in marketing scenarios, you may object to our use
of your personal information.
VI. How We Process the Personal Information of Minors
1. The SUNMI devices are of commercial nature, and
in principle we do not provide services for individuals, including minors.
2. In the case of any personal information collected from minors with the
consent of their parents or legal guardians, we will use or publicly disclose this information only as
permitted by law, with the express consent of the parents or guardians, or as necessary to protect the
minors.
3. If any facts prove that we have collected
personal information from minors without prior consent of verifiable parents or legal guardians, you may
contact us via the contact information set forth herein and we will attempt to delete the relevant
information as soon as we are aware of it.
VII. How the Privacy Policy is Updated
1. This Privacy Policy may change from time to time. We will post any
changes hereto on this page. For significant changes, we will also provide more prominent notices (we may
explain the specific modifications to the Privacy Policy by including but not limited to providing special
tips on the browsing page). We will not reduce your rights under this Privacy Policy without your
express consent.
2. The material changes to this Privacy Policy include, but are not limited
to, significant changes in service model; changes in the main recipients of personal information sharing,
transfer or public disclosure; major changes in your rights to participate in the processing of personal
information and how you exercise them; changes in the department responsible for personal information
security, contact information and complaint channels; when the assessment report for personal information
security impacts indicates high risks.
3. We will also keep an older version of this Privacy Policy on file for
your review.
VIII. How to Contact Us
If you have any questions about this Privacy Policy or the protection of personal information, please
contact us through:
Customer Service Hotline: 400-6666-509
Contact information of the person in charge of personal information protection:
privacy@sunmi.com
In general, we will reply to you within 15 days or within the time limit as provided for by laws. If
you are not satisfied with our reply, especially if you think our personal information processing
behaviors have harmed your legitimate rights and interests, you can also make a complaint or report to the
regulatory departments of cyberspace information, industrial information, public security, and industry
and commerce, or seek a solution by bringing a lawsuit to the court with jurisdiction in the defendant’s
domicile.
Please note that if you are a user in the EEA, the United Kingdom, or Switzerland, you have the
right to complain with the data protection agency in your country.